Text

Proposed Tech Specs Re App J,Primary Reactor Containment Leakage Testing for water-cooled Power Reactors,Option B
	ML20216B620
Person / Time
Site:	San Onofre
Issue date:	05/11/1998
From:	; SOUTHERN CALIFORNIA EDISON CO.
To:	;
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ML20216B568	List: ML20216B562; ML20216B605; ML20216B620;
References
	NUDOCS 9805180273
	Download: ML20216B620 (102)
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Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR.3.6.1.1 Perform required visual examinations and

NOTE-----

leakage rate testing except for containment SR 3.0.2 is not air lock testing, in accordance with applicable 10 CFR 50, Appendix J, as modified by approved exemptions.

In accordance The maximum allowable leakage rate, L., is with 10 CFR 50, 0.10% of containment air weight per day at Appendix J, as the calculated peak containment pressure, modified by P,.

approved.

exemptions J

SR 3.6.1.2 Verify containment structural integrity In accordance in accordance with the Containment Tendon with the Surveillance Program.

Containment Tendon Surveillance Program SAN ON0FRE--UNIT 2 3.6-2 Amendment No. 127.

9905100273 990511 DR ADOCK O gi

~

f l

Containment Air Locks 3.6.2 L il0NS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and 0.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1

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

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2.

Results shall be evaluated against acceptance criteria of SR 3.6.1.1 in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.

Perform required air lock leakage rate

-.--NOTE------

testing in accordance with 10 CFR 50, SR 3.0.2 is not Appendix J, as modified by approved applicable exemptions.

The acceptance criteria for air lock In accordance testing are:

with 10 CFR 50, j

Appendix J, as a.

Overall air lock leakage rate is modified by s 0.05 L, when tested at 2 P,.

approved exemptions b.

For each door, leakage rate is s.01 L, when tested at 2 9.0 psig.

(continued) i l

l SAN ON0FRE--UNIT 2 3.6-6 Amendment No. 127

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls.

previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice Testing Program i

SR 3. 6. 3. 6 - - - - - - - - - - - - - - - - - - N OT E S - - - - - - - - - - - - - - - - - - - - -

Results shall be evaluated against acceptance criteria of SR 3.6.1.1 in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued) l SA*' ON0FRE--ViiIT 2 3.6-14 Amendment No. 127

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals 5.5.2.12 Ventilation Filter Testing Program (VFTP)

(continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VFTP test frequencies.

5.5.2.13 Diesel Fuel Oil Testing Program This program implements required testing of both new fuel oil and stored fuel oil.

The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards.

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-04057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity @ 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-D975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM-D4057-81 and verifying that particulate contamination is less than 10mg/ liter when checked in accordance with ASTM-02276-83, Method A.

I I

SAN ON0FRE--UNIT 2 5.0-20 Amendment No.12f,130

I Containment B 3.6.1 l

BASES SR 3.0.2' not be suitable for conducting the Surveillance (e.g.,

(continued) transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs.

The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is a Surveillance with a frequency of "in i

accordance with 10 CFR 50, Appendix J, as modified by i

approved exemptions." The requirements of regulations take precedence over the TS.

The TS cannot in and of themselves extend a test interval specified in the regulations.

)

Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis. The 25%

extension applies to each performance after the initial performance.

The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action 1

usually verifies that no loss of function has occurred b' checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the.specified limits when a Surveillance has not (continued)

SAN ON0FRE--UNIT 2 B 3.0-12 Amendment No. 127

o Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES e

BACKGROUND The containment consists of the concrete reactor building (RB),itsste.elliner,andthepenetrationsthroughthis structure.

The structure is designed to contain radioactive material that may be released from the reactor core-following a Design Basis Accident (DBA). ' Additionally, this i

structure provides shielding from the fission products that may be present in the containment atmosphere following 1

accident conditions.

I The containment is a reinforced concrete structure with a i

cylindrical wall, a flat foundation mat, and a shallow dome j

roof.

The cylinder wall is prestressed with a post'

]

tensioning system in the vertical and horizontal directions,

{

and the dome roof is arestressed utilizing a three way post tensioning system.

T1e inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

The concrete RB is required for structural integrity of the containment under DBA conditions.

The steel liner and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment. SR 3.6.1.1 leakage rate rec cirements comply with 10 CFR 50, Appendix J (Ref.1), as moc ified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

j 1.

capable of being closed by an OPERABLE automatic containment isolation system, or J

l l

(continued)

I SAN ON0FRE--UNIT 2 B 3.6-1 Amendment No. 127

Containment B 3.6.1 BASES BkCKGROUND 2.

closed by manual valves, blind flangas, or (continued) de-activated automatic valves secured in their closed positions, except as provided in LC0 3.6.3, j

" Containment Isolation Valves."

j 2.

Each air lock is OPERABLE, except as provided in

)

LC0 3.6.2, " Containment Air Locks."

APPLICABLE The safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident, a main steam line break (MSLB), and a control element assembly ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3).

This leakage rate is defined in 10 CFR 50, Appendix J (Ref. 1),

as L.:

the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (P.) of 56.6 psig, which results from the limiting DBA, which is a design basis MSLB (Ref. 5).

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 Containment OPERABILITY is maintained by limiting leakage to within the acceptance criteria of 10 CFR 50, Appendix J (Ref. 1).

Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those l

leakage rates assumed in the safety analysis.

l l

Individual leakage rates specified for the containment air lock (LC0 3.6.2) and purge valves with resilient seals (continued) l SAN ON0FRE--UNIT 2 B 3.6-2 Amendment No. 127 05/31/97 l

l

Containment B 3.6.1 BASES LC0 (LC0 3.6.3) are not specifically part of the acceptance (continued) criteria of 10 CFR 50, Appendix J.

Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the acceptance criteria of Appendix J.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

i ACTIONS A.1 In the event containment is inoperable, containment must ba

)

restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1

Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining j

containment during MODES 1, 2, 3, and 4.

This time period

)

also ensures that the probability of an accident (requiring

?

containment OPERABILITY) occurring during periods when contain~nt is inoperable is minimal.

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ta MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

SAN ON0FRE--UNIT 2 B 3.6-3 Amendment No. 127

I t

Containment B 3.6.1 i

BASES SURVEILLANCE SR 3.6.1 1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions.

Failure to meet air lock and purge valve with resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits.

SR Frequencies are as required by Appendix J, as modified by approved exemptions.

Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the i

Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4),

REFERENCES 1.

10 CFR 50, Appendix J.

2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4 4.

Regulatory Guide 1.35, Revision 3 5.

SONGS Units 2.and 3 UFSAR, Section 6.2 L

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l SAN ON0FRE--UNIT 2 B 3.6-4 Amendment No. 127 05/31/97

Containment Air Locks B 3.6.2 i

B 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks BASES

. BACKGROUND Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation.

Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interiock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and local leakage rate testing ca) ability to ensure

)ressure integrity. To effect a leak tigit seal, the air loc ( design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on cach door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position.

Additionally, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is defeated.

The containment air locks form part of the containment pressure boundary. As such, air lock integrity and 'eak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA.

Not-maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis.

SR 3.6.2.1 leakage rate requirements are in conformance with 10 CFR 50, Appendix J (Ref. 1), as modified 1

by approved exemptions.

(continued)

. SAN ON0FRE--UNIT 2 B 3.6-5 Amendment No. 127 l

V Containment Air Locks B 3.6.2 BASES (continued)

APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a i

loss of coolant accident (LOCA), a main steam line break 1

(MSLB) and a control element assembly (CEA) ejection

)

i I

accident (Ref. 2).

In the analysis of each of these i

accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of O.10% of containment air weight per day (Ref. 2).

This leakage rate is defined in 10 CFR 50, Appendix J (Ref. 1),

as L.:

the maximum allowable containment leakage rate at l

the calculated maximum peak containment pressure (P.)- of 1

56.6 psig, which results from the limiting DBA, which is a j

design basis MSLB (Ref. 3).

This allowable leakage rate i

forms the basis for the acceptance criteria imposed on the SRs associated with the air lock.

i The containment air locks satisfy Criterion 3 of the NRC Policy Statement.

LC0 Each containment air lock forms part of the containment pressure boundary. As part of containment, the air lock safety function is related to control of the containment i

leakage rate resulting from a DBA.

Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE.

The door seals and sealing surface are considered a part of the air lock.

The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events.

Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into l

and exit from containment.

(continued)

SAN ON0FRE--UNIT 2 B 3.6-6 Amendment No. 127 05/31/97 y

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Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.1 (continued)

REQUIREMENTS 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions.

This SR ' reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing.

The periodic testing requirements verify that the air lock i

leakage does not exceed the allowed fraction of the overall

{

Lontainment leakage rate.

The Frequency is required by

{

Appendix J, as modified by approved exemptions. Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

The SR has been modified by two Notes.

Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that air lock leakage is properly accounted for in determining the overall containment leakage rate.

SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock.

Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will suppcrt containment OPERABILITY.

Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur.

Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is only challenged when containment is entered, Note 1 specifies that this test is only required to be performed upon entering containment but is not required more frequently than every 184 days.

The second note states that SR 3.0.4 is not applicable.

The 184 day Frequency is based on engineering judgment and is (continued) l SAN ON0FRE--UNIT 2 B 3.6-11 Amendment No. 127

Containment Air Locks B 3.6.2 i

BASES i

SURVEILLANCE SR 3.6.2.2-(continued)

REQUIREMENTS considered adequate in view of other indications of door and interlock mechanism status available-to operations personnel.

REFERENCES

'1.

10 CFR 50, Appendix J.

2.

UFSAR, Section 15.1, 15.4.

3.

UFSAR, Section 6.2.

l l-l SAN ONOFRE--UNIT 2 B 3.6-12 Amendment No. 127

i Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and l

automatic containment isolation valve is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis.

The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J (Ref. 5), is required to ensure OPERABILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter i

time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref.3).

Additionally, this SR must be performed within 92 days after j

opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

l (continued) l SAN ON0FRE--UNIT 2 B 3.6-25 Amendment No. 127 l

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Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.7 REQUIREMENTS (continued)

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes. Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

i The second note indicates that SR 3.0.4 is not applicable.

]

l SR 3.6.3.8

)

Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures each automatic containment isolation valve will actuate to its isolation position on an actuation signal.

The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J.

i i

i SAN ONOFRE--UNIT 2 B 3.6-26 Amendment No. 127 05/31/97 j

l

Containment Penetrations B 3.9.3 8 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LC0 requirements are met.

In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LC0 3.6.1, " Containment."

In MODE 6, the potential for containment pressurization as a result of an accident is not likely: therefore, requirements to isolate the containment from the outside atmosphere can be less stringent.

The LC0 requirements are referred to as

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment presscrization, the Appendix J leakage criteria and tests ara not required.

The containment serves to r:,ntain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident-conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts.

Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LC0 3.6.2, " Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to l

prevent simultaneous opening when containment OPERABILITY is required.

During periods of shutdown when containment (continued)

SAN ON0FRE--UNIT 2 B 3.9-9 Amendment No. 127 l

1 ATTACHMENT B EXISTING PAGES UNIT 3 1

L Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l

SR 3.6.1.1 Perform required visual _ examinations and

NOTE-----

leakage rate testing except for containment SR 3.0.2 is not air lock testing, in accordance with applicable 10 CFR 50,~ Appendix J, as modified by approved exemptions.

In accordance The maximum allowable leakage rate, L, is with 10 CFR 50, 0.10% of containment air weight per day at Appendix J, as i

the calculated peak containment pressure, modified by P,.

approved exemptions SR 3.6.1.2 Verify containment structural integrity In accordance in accordance with the Containment Tendon with the Surveillance Program.

Containment Tendon Surveillance Program l

i i

l I

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t SAN ON0FRE--UNIT 3 3.6-2 Amendment No.

116

1 1

Containment Air Locks ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME j

l D.

Required Action and 0.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months j

associated Completion Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I

i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1

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

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2.

Results shall be evaluated against acceptance criteria of SR 3.6.1.1 in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, j

q Perform required air lock leakage rate

NOTE------

i testing in accordance with 10 CFR 50, SR 3.0.2 is not Appendix J, as modified by approved applicable exemptions.

The acceptance criteria for air lock In accordance testing are:

with 10 CFR 50, Appendix J, as a.

Overall air lock leakage rate is modified by s 0.05 L, when tested at 2 P.,

approved exemptions b.

For each door, leakage rate is s.01 L, when tested at 2 9.0 psig.

(continued)

SAN ON0FRE--UNIT 3 3.6-6 Amendment No.

116

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from M0DE 5 if i

accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls.

previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice j

Testing Program SR 3.6.3.6------------------NOTES---------------------

Results shall be evaluated against acceptance criteria of SR 3.6.1.1 in accordance with 10 CFR 50, Appena1x J, as modified by approved exemptions.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve t

l (continued)

L l

SAN ON0FRE--UNIT 3 3.6-14 Amendment No.

116 l

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals 5.5.2.12 Ventilation Filter Testing Program (VFTP)

(continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specificatic-Surveillance Requirement 3.0.3 are applicable to the VFTP test frequ'ncies.

5.5.2.13 Diesel Fuel Oil Testing Program This program implements required testing of both new fuel oil and stored fuel oil.

The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards.

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-0975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM-D4057-81 and verifying that particulatecontaminationislessthan10mg/literwhenchecked in accordance with ASTM-D2276-83, Method A.

SAN ON0FRE--UNIT 3 5.0-20 Amendment No, tit,119 4

L Containment B 3.6.1 l

j BASES SR 3.0.2 not be suitable for conducting the Surveillance (e.g.,

)

l (continued) transient conditions or other ongoing Surveillance or

{

l maintenanceactivities).

1 The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the i

SRs.

The exceptions to SR 3.0.2 are those Surve111ances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not appiy is a Surveillance with a Frequency of "in' accordance with 10 CFR 50, Appendix J, as modified by 1

approved exemptions." The requirements of regulations take precedence over the TS..The TS cannot in and of themselves extend a test interval specified in the regulations.

Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."

As stated in SR 3.0.2, the 25% extension-also does not apply to the initial portion of a periodic: Completion Time that requires performance on a "once per..." basis.

The 25%

extension applies to each performance after the initial performance. -The initial performance of the Required j

Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner, i

The provisions of SR 3.0.2 are not intended to be used 1

repeatedly merely as an operational convenience to extend Surveillance intervals or periodic Completion Time intervals

-beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment. inoperable or an affected variable l-outside the specified limits when a Surveillance has not I

l-(continued)

SAN ON0FRE--UNIT 3 B 3.0-12 Amendment No. 116

Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND The. containment consists of the concrete reactor building.

(RB),itssteelliner,andthepenetrationsthroughthis structure.

The structure is designed to contain radioactive material that may be released from the reactor core following a Design Basis Accident (DBA). Additionally, this structure provides shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.

The cylinder wall is prestressed with a post tensioning system in the vertical and. horizontal directions, and the dome roof is arestressed utilizing a three way post tensioning system. T1e inside surface of the containment is

. lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

The concrete RB is required for structural integrity of the containment under DBA conditions. The steel' liner and its penetrations establish the' leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the 1

containment to the environment.

SR 3.6.1.1 leakage rate rec uirements comply with 10 CFR 50, Appendix.J (Ref.1), as mocified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of.the containment leak tight barrier. To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

' SAN ONOFRE--UNIT 3 B 3.6-1 Amendment No. 116 t:

)

Containment B 3.6.1 i

BASES i

BACKGROUND 2.

closed by manual valves, blind flanges, or (continued) de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3, j

" Containment Isolation Valves."

b.

Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks."

APPLICABLE The safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident, a main steam line break (MSLB), and a control element assembly ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3). This leakage rate is defined in 10 CFR 50, Appendix J (Ref. 1),

as L.:

the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (P.) of 56.6 psig, which results from the limiting DBA, which is a design basis MSLB (Ref. 5).

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 Containment OPERABILITY is maintained by limiting leakage to within the acceptance criteria of 10 CFR 50, Appendix J (Ref. 1). Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

lock (LCO 3.6.2)ge rates specified for the containment air Individual leaka and purge valves with resilient seals i

(continued)

SAN ON0FRE--UNIT 3 8 3.6-2 Amendment No. 116 05/31/97

Containmeni B 3.o.1 BASES LC0

.(LC0 3.6.3) are not specifically part of the acceptance (continued) criteria of 10 CFR 50, Appendix J.

Therefore, leakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results in exceeding the acceptance criteria of Appendix J.

I APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.

The requirements for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

ACTIONS A.1 l

In the event containment is ino)erable, ccntainment must be restored to OPERABLE status wit 11n 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months i

Com)letion Time provides a period of time to correct the pro)1em commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4.

This time period also ensures that the probability of an accident (requiring j

containment OPERABILITY) occurring during periods when containment is inoperable is minimal.

B.1 and B.2 l

If containment cannot be restored to OPERABLE status within the required 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

(continued)

-SAN ON0FUE--UNIT 3 B 3.6-3 Amendment No. 116

Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS 1aintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of 10 CFR 50, Appendix J (Ref.1), as modified by approved exemptions.

Failure to meet air lock and purge valve with resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits.

SR Frequencies are as required by Appendix J, as modified by approved exemptions.

Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4).

REFERENCES 1.

10 CFR-50, Appendix J.

2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4 4.

Regulatory Guide 1.35, Revision 3 5.

SONGS Units 2 and 3 UFSAR, Section 6.2 SAN ON0FRE--UNIT 3 8 3.6-4 Amendment No. 116 05/31/97

Containment Air Locks B 3.6.2 8 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks BASES BACKGROUND Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation.

Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end.

The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity.

To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is defeated.

The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA.

Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis. SR 3.6.2.1 leakage rate requirements are in conformance with 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions.

(continued)

. SAN ON0FRE--UNIT 3 8 3.6-5 Amendment No. 116

Containment Air Locks B 3.6.2 l

BASES (continued) i APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a loss of coolant accident (LOCA), a main steam line break (MSLB) and a control element assembly (CEA) ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of j

0.10% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix J (Ref. 1),

as L.: the maximum allowable containment leakage rate at

{

the calculated maximum peak containment pressure (P.) of 56.6 psig, which results from the limiting DBA, which is a design basis MSLB (Ref. 3). This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air lock.

The containment air locks satisfy Criterion 3 of the NRC Policy Statement.

LC0 Each containment air lock forms part of the containment pressure boundary. As part of containment, the air lock safety function is related to control of the containment leakage rate resulting from a DBA.

Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE.

The door seals and sealing surface are considered a part of the air lock.

The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.

Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated everts.

Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into and exit from containment.

(contir.ued)

SAN ON0FRE--UNIT 3 B 3.6-6 Amendment No. 116 05/31/97

E Containment Air Locks B 3.6.2 BASES l

SURVEILLANCE-SR 3.6.2.1 (continued)

REQUIREMFNTS 10 CFR 50, Appendix J (Ref. 1), as modified by approved exemptions. This SR reflects the leakage rate testing.

requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during ini'ial. air lock and containment OPERABILITY testing. The-periodic testing requirements verify that the air lock-l leakaga docs not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by l

Appendix J, as modified by approved exemptions.

Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

The SR has been modified by two Notes. Note 1 states-that L

an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of SR 3.6.~1.1.

This ensures that air lock leakage is properly accounted for in determining the overall containment leakage rate.

l SR ?/.2.2 The air lock interlock is designed to prevent simultaneous l

opening of both doors in-a single air lock.

Since both the 1

inner and outer doors of an air lock are designed to i

l

. withstand the maximum ex)ected post accident containment pressure, closure of.eitler door will support containment OPERABILITY. Thus, the door interlot' feature supports containment OPERABILITY while the air 13..k is being.used for L

personnel transit into and out of containment.

Periodic-testing of this interlock demonstrates that the interlock will function as designed and that' simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is only challenged when L

containment is entered, Note 1 specifies that this test is only required to be performed upon entering containment but is not required more frequently than every 184 days.

The second note states that SR 3.0.4 is not applicable.

The i

184 day Frequency is based on engineering judgment and is i

(continued)

SAN ON0FRE--UNIT 3 8 3.6-11 Amendment No. 116

f Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 (continued)

REQUIREMENTS considered adequate in view of other indications of door and interlock mechanism status available to operations personnel.

I REFERENCES 1.

10 CFR 50, Appendix J.

2.

UFSAR, Section 15.1, 15.4.

3.

UFSAR, Section 6.2.

i i

l l

l SAN ON0FRE--UNIT 3 B 3.6-12 Amendment No. 116

[

Containment Isolation Valves B 3.6.3 l

BASES l

SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis.

The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J (Ref. 5), is required to ensure OPERABILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref. 3).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valvethathasnotbeenopened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

(continued)

SAN ON0FRE--UNIT 3 B 3.6-25 Amendment No. 116 l

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.7 REQUIREMENTS (continued)

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes.

Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA.

This SR ensures each automatic containment isolation valve will actuate to its isolation position on an actuation signal. The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J.

i SAN ON0FRE--UNIT 3 B 3.6-26 Amendment No. 116 05/31/97

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LC0 requirements are met.

In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LC0 3.6.1, " Containment."

In M0DE 6, the potential for containment pressurization as a result of an accident is not likely; ther fore, requirements to isolate the containment from the outside atmosphere can be less stringent.

The LC0 requirements are referred to as

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed.

Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in' place by at least four bolts.

Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LC0 3.6.2, " Containment Air Locks." Each air lock has a door at both ends.

The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required.

During periods of shutdown when containment (continued)

SAN ON0FRE--UNIT 3 B 3.9-9 Amendment No. 116 i

4

\\

t i

i f

ATTACHMENT C PROPOSED PAGES REDLINE AND STRIKE 0UT UNIT 2

Containment J

3.6.1 j

l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and

-- - - -iiG T E- - ---

leakage rate testing except for containment 3R 3.G.2 is nu i.

air lock testing, in accordance with appist.ault 10 CFR 50, Appendia J, as inudificu iey a ppy v ed C ACJJJp k.J uj e.. t h Cbtaimenkl0$kige Raf Tes.tinghProgram; In accordance with 10 CFR 50, 59.L Thej.exi em silew&ble le&kege [5te, 'g,,

is, Appini in 5, as v. A v'.

v i t.v u ca i nincu t asi neigno pc uay a t.

umu i s s eu uy tut t.a s t.u i a tcu pca n t.un ca i nincu t pi cssur c.

appivveu P,7 caciupi. ivns th,,e Containment Le.akapesRati Testing!l Program SR 3.6.1.2 Verify containment structural integrity In accordance in accordance with the Containment Tendon with the Surveillance Program.

Containment Tendon Surveillance Program i

SAN ON0FRE--UNIT 2 3.6-2 Amendment No trt

Containment Air Locks ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 1

l D.

Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion l

Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS l

SURVEILLANCE FREQUENCY l

SR 3.6.2.1

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

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2.

Results shall be evaluated against acceptance criteria of-9.pplicilipibif6 I

SR 3.6.1.1 in acuvrdance wiUi 10 CFh 50, Appendia J, a3 inudified by appi vved cacurpi a vus.

Perform required air lock leakage rate testing in accordance with 10 CFR 50,

NGTE------

i AppendirJ,..ayfusilled.by_appivved 3R 5.0.2 is uvi Sgt.1 ex cnir.i i._u n s.. t he s Con t a i nment1Lec kageiRa te appi i vabi e TestinglProgramt The acucpiance criteria ivr air ivuk In accordance icaiiny aic, with qu urn av, "P P J " ' ^ f ' "

a.

vverais asi avun scanage race is invu i i i eu vy 0.05 Lg WIi6ii t65t6d 6t c IT appiuved 2

I j

exenipiivus til_,e l

b.

Fui cach duvi, itakage iaic is COntalnmeiiff i

.01 L, wheii tested et c 9.0 psig.

LeakagelRate_..

2 Testi.ng? Program (continued)

SAN ON0FRE--UNIT 2 3.6-6 Amendment No. itt i

Containment Isolation Valves 3.6.3 SURVEILLAS:r REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4

NOTES----------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

l

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls, previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice Testing Program SR 3.6.3.6------------------NOTES---------------------

Results shall be evaluated against acceptance criteria Uf a,p))icablh}td SR 3.6.1.1 in accuidance niii 10 CFR 50, Appendia J, as

$T,1 mudiiied by apprvved cacmpiivna.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ON0FP.E--UNIT 2 3.6-14 Amendment No. ttf

Procedures, Programs, and Manuals 5.5 1

5.5 Procedures, Programs, and Manuals (continued) 5.5.2.12-Ventilation Filter Testing Program (VFTP)

(continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VFTP test frequencies.

5.5.2.13 Diesel Fuel Oil Testing Program This program implements required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all.in accordance with applicable ASTM standards.

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to i

addition to the storage tanks by verifying that a sample obtained in acccrdance with ASTM-04057-81 has a water and sediment content of lest than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity @ 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-D975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM-D4057-81 and verifying that particulatecontaminationislessthan10mg/literwhenchecked in accordance with ASTM-D2276-83, Method A.

1 5MkIM Containme'nt t'daka' e' R5tRTestinii, Pro'~rais

^

g g

A program"shall tie esialslished to 1mplement'the'l'~akage rate"testi,ng

~

^ ~ ~

^

e of the containment as, required by 10 CFR 50.54(o) and 10 CFR 50l Appendix J, Option B,,as modified by approved exemptions'. This program shall be in ac,cordance with the, guidelines contained in Regulatory Guide'l.163, " Performance-Based Containment Leak-Test Program," dated September 1995c g"ff7; The ' peak calculate'd containmeiit int'ern'l' pressure for the design

^

~

^ a basis Main Steam,Line Break, P., is 56.6 psige Th'e maxfinum allowable containment le'ak'ag'e' ratef L',, 'at P/, 'sh'all be 0.10% of containment air weight per day. -

SAN ON0FRE--UNIT 2 5.0-20 Amendment No. 1^7,13^

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued)

(Eakigsifit'siiWspli5fe3511bfii[ifsi si ThiiC66filissiiQ~6ViFill$leikijsMiti?ineptihssI6 fit;ifis6;M5, M110%kn0uri ngit hejfi rs t f(Uni tEs t artu pif ol l opi ng)te.s ti ngli n accorda nceiwi th s t_hi s E prog ramigt hsjll eakageg rateraccep ta nce u0M5%$forithelTy)pe/AgestsiMforit heHypesBla nd1Typeltite.s t criterialareM0i60 :

O piEM6MBisi{sifagepishseIEhfliElilifEI 1) 09&illfilhMb'ckil EAKiieRitiliiM0]05;[QWshitisVed atp:sfu 2)'

F6M[sisfi}^d66@iisENi;iksisdifsi$jA0]O1?Qshin pressurized;; tom 910]psig; Ths)fpFdiiij o;ssi6f{SOfVil lldfi n { t he[ Cont ai nmentilea k@ag e; liissl![Riddifim nEj3Id!2 testdrequenciesispecifle Programf0HoweverAtestlfrequencieRspecifiedCinithisIProgramimaysbe extendediconsistent@ithMhe[.guidan_c.e?provi.dedjjin4E.Iy94901L..

"Indu~strylGuidelinego@ImplementingWerformancesBased10ption10f 10CFR s50 $ Appendi UJ inasjendotsedibilResul a torfs;Gui delli163 k.

S peci fi c al l y RN EI) 94h01s h.a sit he s es provi si ons]forst es tif requenci_es,-

extensioni:

Sg.1 Il Consis' tent with sfandard' scheduling praciices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 month's.

This option should be used only in cases where refueling, schedules have been changed to accommodate other factors.

Cons'istent sith' standir' 'schedulihgprac'tices 'for Technical 2!

d

~

Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not, to exceed 15 months.

The provisions of'Sur'veillance 'Requiremfnt 3.0,3 are applicable' to the, Containment Leakage Rate Testing: Program.

SAN ON0FRE--UNIT 2 5.0-20a

SR Applicability B 3.0 BASES SR 3.0.2 not be suitable for conducting the Surveillance (e.g.,

(continued) transient conditions or other ongoing Surveillance or maintenanceactivities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. Ancaampicviwhcic,3R3.^.2 uucs nvo app g, i 3 a aui vc i i i ans.c,w i cry a ricyuenyy v,i in act.viuans.c wicu au crn gv, nypenuin v.

as,muuii,icu uy eppivycu cacmptivna._ suc,iequiscmcuts vi icyuiativus

,L a ne picucuent.c vvci one ia.

ine ia t,annuo in anu vi cucmscirca catenu a oesy. intcivai s pes. i i i cu in one icvuiativns.

3,nci c i vi e,,cucie ia a nucc in.6ne w csucoun acactus, _ _.

ap w.auiy,JniexampleyoffwherekSR. x3:0 notnappl yf+iif tief con t a f nmen tgeakage n Rate 1Tes ti ng,j 2

.doeg# v. s ts an iiv ProgramfuTestifrequencies;specified!1n5thelContainment _

Leakages.RatelTestingiProgramtmaylbe! extended;consistentsWith

$.$.1

glementing;P. erfoded [injNEli94:01@0f5{0CFR15 theiguidanceip~roVi ndustrFEGuidelinejFor Im rmanceEBa_sedE0ption1 dasiend_orsedibylRegulatoryiGuidejl?1631 As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Com)letion Time that requires performance on a "once per..." aasis.

The 25%

extension applies to each performance after the initial performance.

The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually serifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not (continued)

SAN ON0FRE- ') NIT 2 B 3.0-12 Amendment No. tff I

'I Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND The containment consists of the concrete reactor building

]

(RB), its steel liner, and the penetrations through this structure. The structure is designed to contain radioactive material that may be released from the reactor core followingaDesignBasisAccident(DBA). Additionally, this structure provides shielding from the fission products that may be present in the containment atmosphere following q

j accident conditions, j

The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a -shallow dome roof.

The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions, and the dome roof is prestressed utilizing a three way post tensioning system. The inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

The concrete RB is required for structural integrity of the containment under DBA conditions. The steel liner and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.

SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix JE0p66)ilB.

(Ref. 1), as modified by approved exemptions.

l$91 The isolation devices for the penetrations in the i

containment boundary are a part of the containment leak tight barrier.

To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isol tion system, or (continued)

SAN ON0FRE--UNIT 2 B 3.6-1 Amendment No. ttf

Containment B 3.6.1 BASES BACKGROUND 2.

closed by manual valves, blind flanges, or (continued) de-activated automatic valves secured in their closed positions, except as provided in LC0 3.6.3,

" Containment Isolation Valves."

b.

Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks."

APPLICABLE The safety design basis for the containment is that the i'

SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident, a main steam line break (MSLB), and a control element assembly ejectionaccident(Ref.2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3)h0ptis.._..

. T.h.i leakage rate is defined in 10 CFR 50, Appendix J onlB (Ref.1), as L.:

the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (P.) of 56.6 psig, which results from the limiting DBA, which is a design basis MSLB (Ref. 5).

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 Containment OPERABILITY is maintained by 1imiting 1,eakage to Gef. JMj01LjiMMepflipri' $td$thelfMsQ,i. nypenu u otart;upiaftsi l

nionin one acceptance u i tei ia vi av urn av o

pe rfo rmi ngValrequ i red i contai nmen tilea ka gej Ra t eli Te s t i ng 591 Programtleakagettest M Atithisitime @ he1 applicable!1esk_ag..e 1;imitsimustLbe;m.et.

Compliance with this LC0 will ensure a containment i

4 configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

(continued)

SAN ON0FRE--UNIT 2 8 3.6-2 Amendment No. 127 G5/31/^7

Containment B 3.6.1 BASES LC0 Individual leakage rates specified for the containment air (continued) lock (LC0 3.6.2) and purge valves with resilient seals (LC0 3.6.3) are not specifically art,5of th.e acceptance criteria of 10 CFR 50, Appendix J sop'u'a E B..

Therefore, leakage rates exceeding these ind sid l Timits only result in the containment being inoperable when the leakage results in,. exceeding the nspaU acceptance criteria of Append u J H 02.i.,.

g"ffi i

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these

)

MODES.

Therefore, containment is not required to be j

OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

' ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Com)1etion Time provides a period of time to correct the pro)1em commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4.

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

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

t (continued)

SAN ON0FRE--UNIT 2 B 3.6-3 Amendment No. 127

Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of lo CFR 5G, fyyc p g i (Rei. M,asyvdi.iief Programs Failure to meet air lock and purg[,e valve withuz ayyivvcd Sup.1

~

resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B,54kage prior to the first startup aftei and C leakage causes that to exceed limits.I' As left 1 performing a required Containment Leakage Rate Testing Program leakage test is' required to be s 0.6 L for combined Type 8 and C leakage,following an autage or shu,tdown that included Type 8 and C testing'only, and s 0.75 L ' for overall Type A leakage'following an outage or shutdown that included Type A, testing, ' At all other times,between g'Tf 1 required leakage rate tests, the acceptance criteria is_

^

based on an overall Type A leakage limit of s 1.0 L. ' At 41.0 L{' the offsite dose consequences are, bounded by: the assumptonsof,thesafetyanalysis.l,SRFrequenciesareas acquiscu uy,nyycriusa o, as muuisicu uy,ayyivveu,_

cacmyciuns..pecified in'the Containment Leakage Rate Testing Program.' Thus, 'SR 3.'0.2 (which ' allows Frequency exten'sions) does not apply. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and Frequency are-consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4).

REFERENCES 1.

10CFR50,AppendixJElOpM6W[li.

2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4 4.

Regulatory Guide 1.35, Revision 3 5.

SONGS Units 2 and 3 UFSAR, Section 6.2 SAN ONOFRE--UNIT 2 B 3.6-4 Amendment No. 127 G5/31/97

Containment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks BASES BACKGROUND Containment air locks form part of the containmt.9t pressure boundary and provide a means for personnel access during all

. MODES of operation.

Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and. local leakage rate testing ca) ability to ensure pressure integrity.

To effect a leak tigit seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is defeated.

The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis. SR 3.6.2.1 leakage rate requirements are in conformancewith10CFR50,AppendixJK0py]6 NIB (Ref.1),

as modified by approved exemptions.

l5"tf1 (continued)

SAN ON0FRE--UNIT 2 B 3.6-5 Amendment No, tet 1

1

Containment Air Locks B 3.6.2 BASES (continued)

APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a l'

loss of coolant accident (LOCA), a main steam line break (MSLB) and a control element assembly (CEA) ejection l

l accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of-O.10%ofcontainmentairweightperday(Ref.2).d_.This,_.

leakage rate is defined in 10 CFR 50, Appendix J 0ption]B j

l (Ref. 1), as b.

the maximum allowable containment le_akage rateatthecalculated.,nunnwnpeakcontainmentintsynal, pressureFP4(5.6J6Tpsig)i-(-Pr) Of 50.0._ _js, Which R5 ult 5 g"f f j-invin uic inni u ng von, 10]l0 ngfa design basis nu n.n o MSLB(Ref.3).

This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated l

with the air lock.

l The containment air locks satisfy Criterion 3 of the NRC Policy Statement.

l t

LC0 Each containment air lock forms _part of the contajnment.

l pressure boundary. As part of the containment [ pressure L g.1 f

i b.oundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA.

Thus, each air lock's structural integrity and leak tightness are j

essential to the successful mitigation of such an event.

1 l

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with l

the Type B air lock leakage-test, and both air lock doors must be OPERABLE. The door seals and sealing surface are considered a part of the air lock.

The interlock allows l

only one air lock door of an air lock to be opened at one l

time. This provision ensures thai a gross breach of l

containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into amt6@ exit from containment.

(continued) e I

SAN ON0FRE--UNIT 2 8 3.6-6 Amendment No. 127 G5/31/^7

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.1 REQUIREMENTS iv urn av, eppenu.t^ m n m.e41.

unapp3vycu, caenipi. ivn3.the7Containmentileak assuvu m cuagesRate;!Jestin 1 Pro ~~31 T.

This SR reflehts~fhe leakije rite Ediiis ~ ~ g~~' gram

~

requirements with regard to air lock leakage (Type B leakage tests).

The acceptance criteria were established during initial air lock and containment OPERABILITY testing.

The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overali containment leakage rate,. The Frequency is requigu by gpcuuiA g.,as invuisscu uy appi vveu c Acujp c i vn s.

inua, a pph. ash @ifieRiMIMCoilf aliimint[Qa kagilRM@iT@hi g"If'1 a n a. v. c.

gwniun aaiuna riequcucy cacenaiunaj uves uvc Programi The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA.

Note 2 has been added to this SR requiring the

.resul t_s, to,.be,icablego4SR 3.6.1.1.

evaluated against the acceptance criteria Uf whichyisiappl This ensures that air 5"ff1 lock'~15aklagejs_ properly t d for in determining the uveialicombinedjTypesBan,accouned[C containment leakage rate.l591 i

SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock.

Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur.

Due to the purely mechanical natuue of this interlock, and given (continued)

SAN ON0FRE--UNIT 2 B 3.6-11 Amendment No. ttt

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2(continued)

REQUIREMENTS that the interlock mechanism is only challenged when containment is entered, Note 1 specifies that this test is only required to be performed upon entering containment but is not required more frequently than every 184 days. The second note states that SR 3.0.4 is not applicable. The 184 day Frequency is based on engineering judgment and is considered adequate in view of other indications of door and interlock mechanism status available to operations personnel.

REFERENCES 1.

10CFR50,AppendixJDji;@!![5.

2.

UFSAR, Section 15.1, 15.4.

3.

UFSAR, Section 6.2.

l Lpp.1 SAN ONOFRE--UNIT 2 B 3.6-12 Amendment No. tti

Containment Isolation Values B 3.6.3 BASES SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis.

The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate.t.esting beyond the test requirements of 10 CFR 50, Appendix J n0pt; ion 1B (Ref. 5), is required to ensure OPERABILITY.

Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref.3).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened).

Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

(continued)

SAN ON0FRE--UNIT 2 B 3.6-25 Amendment No, ttf

l Containment Isolation Valves B 3.6.3 l

BASES SURVEILLANCE SR 3.6.3.7 REQUIREMENTS (continued)

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes.

Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the vaives are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA.

This SR ensures each automatic containment isolation valve will actuate to its isolation position on an actuation signal.

The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components.

Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix JE0@bih[B.

L p.1 t

SAN ON0FRE--UNIT 2 B 3.6-26 Amendment No. 127 G5/31/^7

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a l

release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LC0 requirements are met.

In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LC0 3.6.1, " Containment."

In i

MODE 6, the potential for containment 3ressurization as a j

result of an accident is not likely; t1erefore, requirements to isolate the containment from the outside atmosphere can j

be less stringent.

The LC0 requirements are referred to as j

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed.

Since there is no potential for containment pressurization, the Appendix J; OptionfB leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LCO 3.6.2, " Containment Air Locks."

Each air lock has a door at both end:,. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required.

During periods of shutdown when containment (continued)

SAN ON0FRE--UNIT 2 B 3.9-9 Amendment No. 127 04/16/97

_7_

ATTACHMENT D PROPOSED PAGES REDLINE AND STRIKE 0UT UNIT 3 t

Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and

NGTE-----

leakage rate testing except for containment 3R 3.G.^

is nui air lock testing, in accordance with applicabie 10CFR50,Appeiidiad,jiC6htaihriiehQliakiid as mvdified by apptuvcu caenipp ung.th In accordance Rateflesting1 Programs with 1G CFR 50, 3"fF1 Thp,7ieximem elicweble le&kege, i ete, 'y, is.

Appesiqixp,as v. 4 v',

v i cuii La n nincii L air wesync pei uay at muusistu uy ilic cal cul aitd peak tviila i siiistill pi cssui t, appivved

,th,e Pi-caemgiiun3 Containment Leakage} Rat (_

TestinglProgram, SR 3.6.1.2 Verify containment structural integrity In accordance in accordance with the Containment Tendon with the Surveillance Program.

Containment Tendon Surveillance Program SAN ON0FRE--UNIT 3 3.6-2 Amendment No. tt6

r 1

Containment Air Locks 3.6.2 l

ACTIONS (continued)

L CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and 0.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated' Completion Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i

i l

1 l

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1

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

1.

An inoperable air lock door does not l

l invalidate the previous successful l

performance of the overall air lock leakage test.

2.

Results shall be evaluated against acceptance criteria ufapplibable36 SR 3.6.1.1 in acuvidance nitii j

10 CFR 50, Appcudia J, as mvdified by 1

appiuved cAcinpiivus.

l Perform required air lock leakage rate l

testing in accordance with 1G CFR 50,

- - - - -iiG I E- - - - - -

Appendia J,lhMCohdinmintNNNiaiERiii as mvdified by iuved 3R 5.G.2 is nui l

}

exempiiuns.

appiiuabie l

JedijilP%irah ~ " ~

~ ~~ - -

buff I {j L

Tiic acucpiance uriieria ivr aii ivuk In accordance ic3 Lins nic.

with 1G CFR 50, 4

nypenuiA d,

a3 Ovci ali a si Ivuk leakage s aic is inudiiied uf a.

0.05 L W!i6ii 163 tid 61 c I'r7 appiuved l

s t

C^C'"Phl.vus Me.

l Centainment_

l u.

rur coun uuvi, scanage iace is

.01 L, niien iested di c 9.0 psis.

LeakageiRate..._

2 l

Testing [ Program (continued)

SAN ON0FRE--UNIT 3 3.6-6 Amendment Nn. tit

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3. 6. 3. 4 - - - - - - - - - - - - - - - - - - N OT E S - - - - - - - - - - - - - - - - - - - -

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is lucated inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within.the under administrative controls.

previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice Testing Program SR 3.6.3.6------------------NOTES---------------------

Results shall be evaluated against acceptance criteria efsbilEibisit6 SR 3.6.1.1 in acuviuaigcwich1GqFR5G,$pecndiaJ,as fyr.1 muuisicu uy appivveu cAcmptivus.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND 1

Within 92 days i

after opening i

the valve (continued) 1 SAN ON0FRE--UNIT 3 3.6-14 Amendment No. tt6

i Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.12 Ventilation Filter Testing Program (VFTP)

(continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VFTP test frequencies.

5.5.2.13 Diesel Fuel Oil Testing Program This program implements required testing of both new fuel oil and stored fuel oil.

The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with l-applicable ASTM standards. The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-0975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil i

'in accordance with ASTM-04057-81 and verifying that L

particulatecontaminationislessthan10mg/11terwhenchecked l

in accordance with ASTM-D2276-83, Method A.

Sl5]2]M ssMil@fli?NsipifftijnijQ15glyE6ifarn FFF6sainsWi113siislibilinFUi3BEEssnEERsNaikaisisis?ianM of&the ?contai nment fa s{requi red [by?10s CFRiS0: 54 (0)landjl0f CFRi SO l Appendi@hallibeMntaccordance:M0ptioniBhasimodifiedibylapprsediese programis 3withithet idE11nesicontai__neddn_

Programi@idGuide3K163MfPerformance4Ba$gu Regul'at6r ed(Containmentileak@ Test

~ ~ ~ ~ ~ ~ ~ ' ~~

^ ~ ~

b"fp.1 athdijeptembid995sj TEF@eil2[Ei1Edlifed?E6HtiihisesKihisesi15FessiiMfdEE#s3esigri basisiMai niS teamf].neiBreaQ P,V11M56161psjg1 TWiiE14EniIii15Wib1REssininiiihilliskiiiIfiiMfChi!M3hiiGi.

0;10Eoficoptainmentila16)eightipgtidah s SAN ON0FRE--UNIT 3 5.0-20 Amendment No.

116,11^

j i

a Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued)

I55kigGiiN?dsplipcesfilsfij((aNI il ThMC66t~ifhiien(6pifilllllsikiisififs?AcEiptihEEIchteFibniii, k%100;lit W}jith1thiEprosrasWthesleakaseirate?accsptance Duringsthelfirstiunittstartupifollowing? testing 11n Xscordance M0ll51Ldfor% 0 (60lLJforiths:(Type 181and1Typeichtes tgand criteriaiare stheXTypeitests; b.9r M,$qd_ o,c k, ~mm. cl. :.~+..., sa w:.,

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SphcificitiohsyReq0iredsSsrieillancesWinfervls1sMorfi;.;._.~_,

Thisjoptionj!TypeTAlbeisedfonlisinjcaseshwhere;.upstok15fmont recommended testingsmay;belextended[by _

should prefueling schedu] es2havej been[; changed !tolaccpmmoda te[otherif actors D

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T6bipF6sistins?66uRi11115ceiksquifsiiiinTWOXaFEaEpMaMilf6 ihel Cont a inmen tAea kage.; Ra.teiTes t i ngiPfog raml SAN ONOFRE--UNIT 3 5.0-20a

SR Applicability B 3.0 BASES SR 3.0.2 not be suitable for conducting the Surveillance (e.g.,

(continued) transient conditions or other ongoing Surveillance or maintenance activities).

l The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification o' conformance with the SRs. The exceptions to SR 3.0.2 are aose Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications.

Ancaaingleviwhcie353.^.^

uves nu6 app p,i3 a aui y e i i i ant.c,n i ui a r i ctiuent.y v,i in act.vi uans.c w i ui av t.rn av, nppenuia 9 asjuuuiijeu uy appiuv,cu cacinp u uns. _ i n e, i c g si cine n 9 3.

i esu i,a y,i una yanc vi pi cs.cuent.c vv e, puc ia.

inc i a,s.annv 6 in anu vg oneniscives i

cucnu a cesy inocivai spct.iiicu ig uic i cs u i a i. i vn s.

i, n c c i v i e,. uici e is a nute i n..u c.pewent.n= c o u ns, _

a,v%g nunap mt.ause.Jnx;exampletof twhere;SRf31_2 an Boesinotyappinisit1e4Contai.nment?LeakageiRatelTesting, P rog ram MTes t1f requenci es? specifi edM nythe n Cont a i nment,..

1 Leaka~gerRate/TestingiProgram;maysbeTextended! consistent!with 3T theigu_1 danc ej prov i dedM n; N Eli94-01$1 ndu s t r# Gu i d el i nlei foi ImglementingjPerformance-BasediOption!0fA10CFRj508 Appendix M assendo g dibyiRegulatoryfGuide21i163g As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Com)letion Time that requires performance on a "once per..."

3 asis.

The 25%

extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason-for not allowing the 25%

i extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

]

)

The provisions of SR 3.0.2 are not intended to be used

{

repeatedly merely as an operational convenience to extend i

Surveillance intervals or periodic Completion Time intervals beyond those specified.

l SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not (continued)

SAN ON0FRE--UNIT 3 8 3.0-12 Amendment No. tift

Containment B 3.6.1 f

B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment l

1 l

f BASES l

BACKGROUND The containment consists of the concrete reactor building l

(RB), its steel liner, and the penetrations through this structure. The structure is designed to contain radioactive material that may be released from the reactor core following a Design Basis Accident (DBA). Additionally, this structure provides shielding from the fission products that may be present in the containment atmosphere following accident conditions.

l The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof. The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions, and the dome roof is arestressed utilizing a three way post l

tensioning system. T1e inside surface of the containment is i

lined with a carbon steel liner to ensure a high degree of j

leak tightness during operating and accident conditions.

l The concrete RB is required for structural integrity of the l

containment under DBA conditions. The steel liner and its

)

penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.

SR 3.6.1.1 leaka requirements comply with 10 CFR 50, Appendix J@ge ratept M B,

'(Ref. 1), as modified by approved exemptions.

lb.y.1 The isolation devices for the penetrations in ;.he containment boundary are a part of the containunt leak tight barrier. To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic l

containment isolation system, or (continued)

SAN ON0FRE--UNIT 3 8 3.6-1 Amendment No. tit

Containment B 3.6.1 1

BASES

\\

BACKGROUND 2.

closed by manual valves, blind flanges, or (continued) de-activated automatic valves secured in their closed 3

positions, except as provided in LCO 3.6.3,

" Containment Isolation Valves."

l b.

Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks."

{

APPLICABLE The safetv design basis for the containment is that the SAFETY ANALYSES containmut must withstand the pressures ad temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident, a main steam line break (MSLB), and a control element assembly ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that Untainment is OPERABLE such that release of fission products a the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3)R6p.his_fB T

leakage rate is defined in 10 CFR 50, Appendix J tfon.

q (Ref.1), as L.:

the maximum allowable containment le~akage rate at the calculated maximum peak containment pressure (P.) of 56.6 psig, which results from the limiting DBA, whichisadesignbasisMSLB(Ref.5).

Satisfactory leakage rate test results are a requirement for the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

- LC0 Containment OPERABILITY is maintained by limiting leakage to wiunn use acucycance uriceria vi iv urn npyeuu m o Esf JWOM%6djitis?ib$63thelf@R.atelTestinsu,stap performiri sairequ)re#ContainmentMakaget g"ff-ProgramM. kagelt esN Atithi,sy t i meMthg. appl i cabl e}] illa._ _

ge 1.imitsimustj belme.ti Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

(continued)

SAN ON0FRE--UNIT 3 8 3.6-2 Amendment No.

116 G5/31/^7

Q cainment B 3.6.1 BASES Individ'ual leaka LC0 lock.(LC0'3.6.2)ge rates specified for the containment air (continued) and purge valves with resilient seals (LC0 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, ~ Ap)endix Jg0ph6hi8. Therefore, leakage rates exceeding t1ese individdil' Timits only result in the containment bein inoparable when the leakage results i

eeding the 6 hkli acceptance criteria of Appmuu J 5,g,1 APPLICABILITY In MODES 4, 2, 3, and 4, a DBA 'could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.

The requirements.for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a 3eriod of time to correct the problem commensurate with t1e importance of maintaining-containment during MODES 1, 2, 3, and 4.

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

B.1 and B.2 If containment cannot be restored to OPERABLE. status within the required 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

(continued)

SAN ONOFRE--UNIT 3 8 3.6-3 Amendment No. tt6

Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirementsof10Cris50.,jypendj (Tyc i. j),. a 3,.guij ij eg uy,apptuvedcacuipbun3.)hejcontain.4.,y.mekt1LeakagegRatelTesting

$ opp.1 Program; Failure to meet air lock and purge valve with resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does rot invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A,f;1eakd C, lea.kage,.causes_ thal to,exce,ed._a B,,an l

perfo.rmi.Jsj:

limits..

1Ef m

ngra guned3Containmentileakage;RateHest..ing.._..

Program)1eak@ageitestyistrequireditotheas0j6s:L.[foricombined TypeBiland;C}1eakagenfollowingian;outagesordsh tdown;1that l

f ncl uded gypels lLandKCjtesting; onlyRandisi;0175Mfol oj epa 11 NTypeM sl e a kagedo110wi ng talnioutagesord s hu tdownith_a t Sqe.1 includeOTy efMtestingMAtialliothestimesSbetween EsquiredElekapsfrateiteitsMthsQcc'eptandesspitsriayis.

ba sedl6rifanloverallsType1All sakagefl imi tiofM110! ti 1At niiO Mthei dffsi tsidossis6nsequencesiafe$odnded dNhs

aisunt}or#@fstheMfetdanaQsis{fSRFYequenciesafe~as icquincu uy pypcuuia o, as muusiseu uy o

>psuvcu PsgriQ Thus, SR'31[0.T(which~allowi^Fisquenc.i enenitonsca i

does not apply.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

I SR 3.6.1.2 l

For ungroui.cd, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4),

i I

REFERENCES 1..

10CFR50,AppendixJE05{id[B.

4 2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4

)

4.

Regulatory Guide 1.35, Revision 3 1

5.

SONGS Units 2 and 3 UFSAR, Section 6.2 ls91 SAN ON0FRE--UNIT 3 B 3.6-4 Amendment No.

116 G5/31/97 1

)

i

l Contairment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks l

BASES BACKGROUND Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation.

Each air lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity.

To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in' containment internal pressure results in increased sealing force on each door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is defeated.

The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis.

SR 3.6.2.1 leakage rate requirements are ia conformance with 10 CFR 50, Appendix JR0ption?B (Ref.1),

as modified by approved exemptions.

]591 I

i (continued)

SAN ON0FRE--UNIT 3 8 3.6-5 Amendment No. tt6

Containment Air Locks l

B 3.6.2 l

l BASES (continued)

APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a loss of coolant accident (LOCA), a main steam line break (MSLB) and a control element assembly (CEA) ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 2)H0ptiohlB This leakage rate is defined in 10 CFR 50, Appendix J (Ref. 1), as t.

the maximum allowable containment leakage i

i rate at the calculated _.nnrxTmmir peak containment hjNM pressureQM(Lus DBA, whkh of6116Ai$ng a, design basis MS lH7 56j63sig)-%) ef 50.0 gjg which results S

ii um u s i nin

[-

(Ref.3). This allowable leakage rate forms the basis for l

the acceptance criteria imposed on the SRs associated with the air lock.

The containment air locks satisfy Criterion 3 of the NRC l

Policy Statement.

LC0 Each containment air lock forms part of the containment pressure boundary.

As part of the containmentipsiju@

gg,1 boundary, the air lock safety f6detion is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock l

l to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with I

the Type B air lock leakage test, and both air lock doors must be OPERABLE.

The door seals and sealing surface are considered a part of the air lock. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed l

when.the air lock is not being used for normal entry into l-arntos exit from containment.

(continued) f SAN ON0FRE--UNIT 3 B 3.6-6 Amendment No.

116 G5/31/^7 i

)

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.1 REQUIREMENTS 10 CFR 50, bppendia d (Rei. 1) as mvdifica by d

This SR reflects the~;Iiminj@akij[ rat @Tsjlinydg pivverug 5 (r.1 caempiiun3.thelCohYit leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing.

The i

periodic testing requirements verify that the air lock i

leakage does not exceed the allowed fraction of the overall containment leakage rat;e,. The Frequency is icqui gu by 5*ff 1 nppesiuir u, as muusiseu uy appivveu caemptivna.

inus, 3R 5.G.2 (wiiit.ii olivws Fr equent.

dues nui 3FP!7-ENS $Mfisd@ihEC6nlahex ien s i uns) sir lat nthiaksg Program?

f The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this.SR requiring the Whichli_to,be evalua.ted against the acceptance criteria of l S pg.1 results ss.applic.E_blefto SR 3.6.1'.1.

This ensures that air uver alicombisdMypgBjland10 containment leakage rate.

l 5-te 1 l

i SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum ex)ected post accident containment pressure, closure of eitler door will support containment OPERABILITY. Thus, the door interlock feature supports j

containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur.

Due to the purely mechanical nature of this interlock, and given (continued)

SAN ON0FRE--UNIT 3 B 3.6-11 Amendment No. tt6

Containment Air Locks B 3.6.2 BASES l

SURVEILLANCE SR 3.6.2.2 (continued) l REQUIREMENTS l

that the interlock mechanism is only challenged when l

containment is entered, Note 1 specifies that this test is l

only required to be performed upon entering containment but l

is not required more frequently than every 184 days. The l

second note states that SR 3.0.4 is not applicable. The 184 day Frequency is based on engineering judgment and is considered adequate in view of other indications of door and i

interlock mechanism status available to operations l

personnel.

r i

i REFERENCES 1.

10CFRCO,AppendixJ![0Epiis]p.

l 2.

UFSAR, Section 15.1, 15.4.

i 3.

UFSAR, Section 6.7..

15att 1 i

1 l

l l

i f

SAN ON0FRE--UNIT 3 8 3.6-12 Amendment No. ttt

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is i

required to demonstrate OPERABILITY. The isolation time l

test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis.

The l

isolation time and Frequency of this SR are in accordance l.

with the Inservice Testing Program.

SR 3.6.3.6 l

For containment purge valves with resilient seals, i

additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix Jg0ptiohjj (Ref. 5), is required to L

ensure OPERABILITY. Operating experience has demonstrated i

that this type of seal has the potential to degrade in a shorter time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days l

was established as part of the NRC resolution of Generic l

Issue B-20, " Containment Leakage Due to Seal Deterioration" l

(Ref.3).

Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the

[

interval (from 184 days) is a prudent measure after a valve l

has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

(continued) j 1

SAN ON0FRE--UNIT 3 B 3.6-25 Amendment No. Mf7 L

Containment Isolation Valves B 3.6.3 BASES i

SURVEILLANCE SR 3.6.3.7 REQUIREMENTS (continued)

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated j

frequency.This SR is modified by two notes.

Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

l SR 3.6.3.8 Automatic containment isolation valves close on an actuation

)

signal to prevent leakage of radioactive material from j

containment following a DBA.

This SR ensures each automatic j

containment isolation valve will actuate to its isolation position on an actuation signal.

The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10CFR50,AppendixJIl0didEs.

Sqp.1 l SAN ON0FRE--UNIT 3 B 3.6-26 Amendment No. 116 G5/31/97

Containment Penetrations B 3.9.3 8 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies j

within containment with irradiated fuel in containment, a i

release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LC0 requirements are met.

In MODES 1, 2, 3, and 4, this is accomplished by mainta m'ng containment OPERABLE as described in LC0 3.6.1, "Contaivet."

In MODE 6, the potential for containment 3ressur ization as a i

result of an accident is not likely; t1erefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LC0 requirements are referred to as

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed.

Since there is no potential for containment pressurization, the Appendix Jj OptioMBleakagecriteriaandtestsarenotrequired.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts.

Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LC0 3.6.2, " Containment Air Locks."

Each air lock has a door at both ends.

The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

SAN ONOFRE--UNIT 3 B 3.9-9 Amendment No. tit

1 ATTACHMENT E UNIT 2 PROPOSED PAGES

Containment 3.6.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and' In accordance leakage rate testing except for containment with the air lock testing, in accordance with the Containment Containment Leakage Rate Testing Program.

Leakage Rate Testing Program SR 3.6.1.2

. Verify containment structural integrity In accordance

' n accordance with the Containment Tendon with the i

Surveillance Program.

Containment Tendon Surveillance Program

- SAN ON0FRE--UNIT 2 3.6-2

l Containment Air Locks 3.6.2 i

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion

)

Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

)

l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1

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

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leaka.,e test.

2.

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

i Perform required air lock leakage rate In accordance testing in accordance with the Containment with the Leakage Rate Testing Program.

Containment Leakage Rate Testing Program (continued) l

)

i SAN ON0FRE--UNIT 2 3.6-6 i

i

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS -(continued)

SURVEILLANCE FREQUENCY SR -3.6.3.4

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

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4'is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls, previous 92 days SR ~ 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice-Testing Program SR 3. 6. 3. 6 - - - - - - - - - - - - - - - - - - N OT ES - - - - - - - - - - - - - - - - - - - - -

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ON0FRE--UNIT 2-3.6-14 1

i t

Procedures, Programs, and Manuals 5.5 5.5 Procedures,. Programs, and Manuals (continued) 5.5.2.12 Ventilation Filter Testing Program (VFTP)

(continued) i The provisions of Technical Specification Surveillance Requirement i

3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are l

applicable to the VFTP test frequencies.

l 5.5.2.13 Diesel Fuel 011 Testing Program This program implements required testing of both new fuel oil and stored fuel oil.

The program shall include sampling and testing re'uirements, and acceptance criteria, all in accordance with-q applicable ASTM standards. The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-0975-81.

]

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM-D4057-81 and verifying that particulatecontaminationislessthan10mg/literwhenchecked in accordance with ASTM-D2276-83, Method A.

5.5.2.14 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995.

The peak calculated containment internal pressure for the design basis Main Steam Line Break, P., is 56.6 psig.

The maximum allowable containment leakage rate, L., at P., shall be 0.10% of containment air weight per day.

l SAN ON0FRE--UNIT 2 5.0-20

Procedures, Programs, and Manuals

{

5.5 5.5 Procedures, Programs, and Manuals (continued)

Leakage rate acceptance criteria are:

a.

The Containment overall leakage rate acceptance criterion is s 1. 0 L,.

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the Type B and Type C tests and s 0.75 L, for the Type A tests; b.

Air lock testing acceptance criteria are:

1)

Overall air lock leakage rate is s 0.05 L, when tested at 2 P,.

2)

For each door, the leakage rate is s 0.01 L, when pressurized to 2 9.0 psig.

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01,

" Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163.

Specifically, NEI 94-01 has these provisions for test frequencies extension:

2.

Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months.

This option should be used only in cases where refueling schedules have been changed to accommodate other factors.

2.

Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

SAN ON0FRE--UNIT 2 5.0-20a

l SR Applicability B 3.0 BASES

)

SR 3.0.2 not be suitable for conducting the Surveillance (e.g.,

(continued) transient conditions or other ongoing Surveillance or maintenanceactivities).

The 25% extension does not significantly degrade the I

reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs.

The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is the Containment Leakage Rate Testing Program.

Test frequencies specified in the Containment Leakage Rate Testing Program may be extended consistent with the guidance provided in NEI 94-01," Industry Guideline For J,glementingPerformance-BasedOptionOf10CFR50, Appendix Im as endorsed by Regulatory Guide 1.163.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Com)1etion Time that requires performance on a "once'per..."

3 asis.

The 25%

extension applies to each performance after the initial performance. The initial performanc'; of_the Required Action, whetic it is a particular Surveillance or some other remedial at.Jon, is considered a single action with a single Completion Tin,:

0..c reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundar,t or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly wely as an operational convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not i

l l

1 (continued)

SAN ON0FRE--UNIT 2 B 3.0-12 i

(

l L

l Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS 1

B 3.6.1 Containment i

BASES

)

BACKGROUND The containment consists of the concrete reactor building l

(RB), its steel liner, and the penetrations through this

]

structure. The structure is designed to contain radioactive 1

material that may be released from the reactor core following a Design Basis Accident (DBA).

Additionally, this structure provides shielding from the fission products that may be present in the containment atmosphere following j

accident conditions.

The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.

The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions, j

and the dome roof is prestressed utilizing a three way post tensioning system. The inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions.

]

The concrete RB is required for structural integrity of the containment under DBA conditions. The steel liner and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.

SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix J, Option B (Ref. 1), as modified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier.

To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or i

(continued)

SAN ON0FRE--UNIT 2 8 3.6-1

Containment-B 3.6.1 BASES BACKGROUND 2.

closed by manual valves, blind flanges, or

-(continued) de-activated automatic valves secured in their closed positions, except as provided in LC0 3.6.3,

" Containment Isolation Valves."

b.

Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks."

APPLICABLE' The. safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a ' release of radioactive material within containment are a loss of coolant accident, a main steam line break (MSLB), and a control element assembly ejection accident (Ref. 2).

In the' analysis of each of these accidents, it is assumed that containment is OPERABLE i

such that release of fission products to the environment is j

controlled by'the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3).

This.

leakage rate is defined in 10 CFR 50, Appendix J Option B l

1 (Ref.1), as L.:

the maximum allowable containment leakage rate at the calculated maximum peak containment pressure

]

(P.) of 56.6 psig, which results from the limiting DBA, which is a design basis MSLB (Ref. 5).

Satisfactory leakage rate test results are a requirement for

)

the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 Containment OPERABILITY is maintained by limiting leakage to 5: 1.0 L, except prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test. At this time, the applicable leakage limits must be met.

Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit. leakage to those leakage rates assumed in the safety analysis.

(continued)

SAN.0N0FRE--UNIT 2-B 3.6-2

r Containment B 3.6.1 i

BASES

]

LC0 Individual leakage rates specified for the containment air l

(continued) lock (LC0 3.6.2) and purge valves with resilient seals (LC0 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix J, Option B.

Therefore, i

l 1eakage rates exceeding these individual limits only result in the containment being inoperable when the leakage results l

in exceeding the overall acceptance criteria of 1.0 L,.

l l

i APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.

The requirements for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Com)1etion Time provides a period of time to correct the pro)1em commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4.

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

l B.1 and B.2 If containment cannot be restored to OPERABLE status within l

the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant nust be brought tr at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating l

experience, to reach the required plant conditions from full l

power conditions in an orderly manner and without it challenging plant systems.

I (continued) i SAN ON0FRE--UNIT 2 B 3.6-3

Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of the Containment Leakage Rate Testing Program.

Failure to meet air lock and purge valve with resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As lef t leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be s 0.6 L, for combined Type B and C lev >tge following an outage or shutdown that included Type B.nd C testing only, and s 0.75 L, for overall Type A leakage following an outage or shutdown that included Type A testing. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L,.

At s 1.0 L, the offsite dose consequences are bounded by the assumptions of the safety analysis.

SR Frequencies are as specified in the Containment Leakage Rate Testing Program.

Thus, SR 3.0.2 (which allows Frequency extensions) does not apply.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be i

maintained in accordance with the provisions of the Containment Tendon Surveillance Program. lesting and i

Frequency are consistent with the recommendations of l

Regulatory Guide 1.35 (Ref. 4).

REFERENCES 1.

10 CFR 50, Appendix J, Option B.

l 2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4 l

4.

Regulatory Guide 1.35, Revision 3 5.

SONGS Units 2 and 3 UFSAR, Section 6.2 i

l SAN ON0FRE--UNIT 2 B 3.6-4

Containment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks BASES BACKGROUND Containment air locks forrn part of the containment pressure boundary and provide a means for personnel access during all MODES of operation.

Each oir lock is nominally a right circular cylinder,10 ft in diameter, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity.

To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operater whenever an air lock door interlock mechanism is defeated.

The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA.

Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis.

SR 3.6.2.1 leakage rate requirements are in conformance with 10 CFR 50, Appendix J, Option B (Pef. 1),

l as modified by approved exemptions.

(continued)

SAN ON0FRE--UNIT 2 B 3.6-5

Containment Air Locks B 3.6.2 BASES (continued)

APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a loss of coolant accident (LOCA), a main steam line break (MSLB) and a control element assembly (CEA) ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPCRABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix J, Option B (Ri.f.1), as the maximum allowable containment leakage rate at the calculated peak containment internal pressure, P.

(56.6 )sig), following a design basis MSLB (Ref. 3).

This allowa)le leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with tht. air lock.

The containment air locks satisfy Criterion 3 of the NRC Policy Statement.

LC0 Each containment air lock forms ) art of the containment pressure boundary. As part of t1e containment pressure boundary, the air lock safety function is related to control I

of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The door seals and sealing surface are considered a part of the air lock. The interlock allows only one air lock door of an air lock to be oper.ed at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.

Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both Mors are kept closed when the air lock is not being used for normal entry into or l

exit from containment.

(continued)

SAN ON0FRE--UNIT 2 B 3.6-6 l

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.1 REQUIREMENTS the Containment Leakage Rate Testing PNgram.

This SR l

reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests).

The acceptance criteria were established during initial air lock and containment OPERABILITY testing.

The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is as specified in the Containment Leakage Rate Testing Program.

The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lack door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1.

This ensures that air l

lock leakage is properly accounted for in determining the combined Type B and C containment leakage rate.

l SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock.

Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure, closure of either door will support containment OPERABILITY.

Thus, the door interlock feature supports containment OPERABILITY while the ai.* lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and cuter doors will not inadvertently occur.

Due to the purely niechanical nature of this interlock, and given (continued) l SAN ON0FRE--UNIT 2 B 3.6-11

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 (continued)

REQUIREMENTS that the interlock mechanism is only challenged when containment is entered, Note 1 specifies that this test is only required to be performed upon entering containment but is not required more frequently than every 184 days. The second note states that SR 3.0.4 is not applicable. The i

184 day Frequency is based on engineering judgment and is considered adequate in view of other indications of door and interlock mechanism status available to operations personnel.

REFERENCES 1.

10 CFR 50, Appendix J, Option B.

l 2.

UFSAR, Section 15.1, 15.4.

3.

UFSAR, Section 6.2.

l l

SAN ON0FRE--UNIT 2 8 3.6-12

Containment Isolation Valves B 3.6.3 BASES 4

SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B (Ref. 5), is required to ensure OPERABILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref. 3).

Additionally, this SR must be performed within 92 days after opening the valve.

The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened).

Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated

)

against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY.

i (continued)

SAN ON0FRE--UNIT 2 B 3.6-25

Containment Isolation Valves B 3.6.3 i

BASES SURVEILLANCE SR 3.6.3.7

)

REQUIREMENTS j

(continued)-

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes. Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 Automatic containment isolation valves close on an actuation signal to prevent-leakage of radioactive material from containment following a DBA. This SR ensures each automatic centainment isolation valve will actuate to its isolation position on an actuation signal. The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components.

Operating experience has shown that these components usually pass this SR when performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

)

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J, Option B.

l SAN ON0FRE--UNIT'2-

'B 3.6-26

Containment Penetrations B 3.9.3 8 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of f'rel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment'when the LC0 requirements are met.

In MODES 1, 2, 3, and 4,.this is accomplished by maintaining containment OPERABLE as described in LC0 3.6.1, " Containment."

In MODE 6, the potential for containment 3ressurization as a result of an accident is not likely; t1erefore, requirements to. isolate the containment from the outside atmosphere can be less-stringent. The LCO. requirements are referred to as-

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J, Option B leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within _ the requirements of 10 -CFP 100.

Additionally, the containment-structure provides radiation shielding from the fission products that may be prer.ent in the containment atmosphere following accident' conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel asremblies within containment, the equipment hatch must be held in place by at least four bolts.

Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means _for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LC0 3.6.2, " Containment Air Locks." Each air lock has-a door at both ends.

The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

SAN ON0FRE--UNIT 2 B 3.9-9

ATTACHMENT F UNIT 3 PROPOSED PAGES

Containment 3.6.1 SUP.VEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1 Perform required visual examinations and In accordance leakage rate testing except for containment with the air lock testing, in accordance with the Containment Containment Leakage Rate Testing. Program.

Leakage Rate Testing Program SR 3.6.1.2 Verify containment structural integrity In accordance in accordance with the Containment Tendon with the Surveillance Program.

Containment Tendon Surveillance Program SAN ONOFRE--UNIT 3 3.6-2

Containment Air c

ACTIONS (continued)

CONDITION REQUIRED ACTION fCOMPLETIONTIME D.

Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1

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

1.

An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2.

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform required air lock leakage rate In accordance testing in accordance with the Containment with the Leakage Rate Testing Program.

Containment Leakage Rate Testing Program (continued)

SAN ON0FRE--UNIT 3' 3.6-6

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) l 1

l SURVEILLANCE FREQUENCY l

SR 3. 6. 3. 4 - - - - - - - - - - - - -- - - - - N OT E S - - - - - - - - - - - - - - - - - - - -

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that_is located'inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is' closed, except i'or not performed containment isolation valves that are open within the under administrative cont.'ols.

previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A

'In accordance and B power operated and each automatic with the containment isolation valve is within limits.

Inservice i

Testing Program j

.SR 3.6.3.6------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1 l

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

' SAN'0NOFRE--UNIT 3 3.6-14

Procedures, Programs, and Manuals 5.5 i

5.5 Procedures, Programs,andManuals(continued) 5.5.2.12 Ventilation Filter Testing Program (VFTP)

(ccntinued) 1 The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VFTP test frequencies.

5.5.2.13 Diesel Fuel Oil Testing Program l

This program implements required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards.

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-0975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM-D4057-81 and verifying that particulate contamination is less than 10mg/ liter when checked in accordance with ASTM-D2276-83, Method A.

5.5.2.14 Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by'10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be-in accordance with.the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program", dated September 1995.

The peak calculated containment internal pressure for the design basis Main Steam Line Break, P., is 56.6 psig.

The maximum allowable containment leakage rate, L., at P,, shall be 0.10% of containment air weight per day.

2 SAN ON0FRE--UNIT 3 5.0-20 i

i

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued)

Leakage rate acceptance criteria are:

a.

The Containment overall leakage rate acceptance criterion is s 1. 0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the Type B and Type C tests and s 0.75 L, for the Type A tests; i

b.

Air lock testing acceptance criteria are:

1 1)

Overall air lock leakage rate is s 0.05 L, when tested a t 2 P,.

2)

For each door, the leakage rate is s 0.01 L, when pressurized to 2 9.0 psig.

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01,

" Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163.

Specifically, NEI 94-01 has these provisions for test frequencies extension:

1.

Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months.

This option should be used only in cases where refueling schedules have been changed to accommodate other factors.

2.

Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test l

interval, not to exceed 15 months.

{

The provisions of Surveillance Requirement 3.0.3 are applicable to 1

the Containment Leakage Rate Testing Program.

SAN ON0FRE--UNIT 3 5.0-20a

SR Applicability B 3.0 BASES SR' 3.0.2 not be suitable for conducting the Surveillance (e.g.,

(continued) transient conditions or other ongoing Surveillance or maintenanceactivities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is the Containment Leakage Rate Testing Program. Test frequencies specified in the Containment Leakage Rate Testing Program may be extended consistent with the guidance )rovided in NEI 94-01," Industry Guideline for J,p' as endorsed by Regulatory Guide 1.163;Im lementing

)erformance-Based Option Of 10CFR 50, Appendix As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Com)1etion Time that requires performance on a "once per..."

) asis.

The 25%

extension applies to each performance after the initial performance.

The initial performance of the Required Action, whether it is a particular Surveillance or some-other remedial action, is considered a single action with a

-single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience'to extend Surveillance intervals or periodic Completion Time intervals beyond those.specified.

-SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not (continued)

SAN ON0FRE--UNIT 3 8 3.0-12

1 Containment B 3.6.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment BASES BACKGROUND The containment consists of the concrete reactor building (RB), its steel liner, and the penetrations through this structure.

The structure is designed to contain radioactive material that may be released from the reactor core following a Design Basis Accident (DBA). Additionally, this structure provides shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.

The cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions, and the dome roof is prestressed utilizing a three way post tensioning system. The inside surface of the cantainment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident co.'ditions.

The concrete RB is required for structural integrity of the containment under DBA conditions.

The steel liner and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment.

SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix J, Option B l

(Ref. 1), as modified by approved exemptions.

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier.

To maintain this leak tight barrier:

a.

All penetrations required to be closed during accident conditions are either:

1.

capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

SAN ON0FRE--UNIT 3 8 3.6-1 n

Containment B 3.6.1 BASES BACKGROUND 2.

closed by manual valves, blind flanges, or (continued) de-activated automatic valves secured in their closed positions, except as provided in LCO 3.6.3,

" Containment Isolation Valves."

b.

Each air lock is OPERABLE, except as provided in LC0 3.6.2, " Containment Air Locks."

APPLICABLE The safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant acci.ent, a main steam line break (MSLB), and a control eleme.t assenbly ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 3).

This leakage rate is defined in 10 CFR 50, Appendix J, Option B l

(Ref.1), as L,:

the maximum allowable containment leakage rate at the calculated maximum peak containment pressure (P,) of 56.6 psig, which results from the limiting DBA, which is a design. basis MSLB (Ref. 5).

Satisfactory leakage rate test results are a requirement for j

the establishment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LC0 Containment OPERABILITY is maintained by limiting leakage to s 1.0 L, except prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test. At this time, the applicable leakage limits must be met.

Compliance with this LC0 will ensure a containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analysis.

(continued)

-SAN ONOFRE--UNIT 3 8 3.6-2

1 Containment B 3.6.1 BASES LC0 Individual leaka lock (LCO 3.6.2)ge rates specified for the containment air (continued) and purge valves with resilient seals (LC0 3.6.3) are not specifically part of the acceptance criteria of 10 CFR 50, Appendix-J, Option B.

Therefore, l

leakage rates exceeding these individual limin only result in the containment being inoperable when the leakage results in exceeding the overall acceptance criteria of 1.0 L.,

l APPLICABILITY In MODES 1~, 2, 3, and 4, a DBA could cause a release of radioactive material into containment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not reqaired to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment.

The requirements for containment during MODE 6 are addressed in LC0 3.9.3, " Containment Penetrations."

ACTIONS A.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a 3eriod of time to correct the problem commensurate with t1e importance of maintiining containment during MODES 1, 2, 3, and 4.

This time period also ensures that the p)robability of an accident (requiring containment OPERABILITY occurring during periods when containment is inoperable is minimal.

B.1 and B.2 If containment cannot be restored to OPERABLE status within the required 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

SAN ON0FRE--UNIT 3 B 3.6-3

Containment B 3.6.1 BASES SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements of the Containment Leakage Rate Testing Program.

Failure to meet air lock and purge valve with resilient seal leakage limits specified in LC0 3.6.2 and LC0 3.6.3 does not invalidate the acceptability of these l

overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program leakage test is required to be s 0.6 L, for combined Type B and C leakage following an outage or shutdown that included Type B and C testing only, and s 0.75 L for overallTypeAleakagefollowinganoutageorsh$tdownthat included Type A testing. At all other times between required leakage rate testc, the acceptance criteria is based on an overall Type A ?eakage limit of s 1.0 L. At s 1.0 L, the offsite dose casequences are bounded by the assumptions of the safety anal / sis. SR Frequencies are as specified in the Containment Leakage Rate Testing Program.

Thus, SR 3.0.2-(which allows Frequency extensions) does not apply.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

_S R 3 6.1.2 t

For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. _ Testing and Frequency are consistent with the recommendations of RegulatoryGuide1.35(Ref.4).

REFERENCES _

1.

10 CFR 50, Appendix J, Option B.

l 2.

SONGS Units 2 and 3 UFSAR, Section 15.1 3.

SONGS Units 2 and 3 UFSAR, Section 15.4 4.

Regulatory Guide 1.35, Revision 3 5.

SONGS Units 2 and 3 UFSAR, Section 6.2 SAN ON0FRE--UNIT 3 8 3.6-4 l

1

(:

Containment Air Locks B 3.6.2 L

B_3.6 CONTAINMENT SYSTEMS l

B 3.6.2 Containment Air Locks BASES BACKGROUND Containment air locks form part of the containment pressure l

boundary and provide.a means for_ personnel access during all MODES of operation.

Each air lock is nominally a right circular cylinder,10 ft l

in diameter, with a door at each end. The doors _are

'~

interlocked to prevent simultaneous opening.

During periods when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods wnen frequent containment entry is necessary.

Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports containment OPERABILITY.

Each of the doors contains double gasketed seals and local leakage rate testing capability to o

ensure aressure integrity.

To effect a leak tight seal, the air loc c design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).

Each personnel air lock is provided with limit switches on both doors that provide control room indication of door position. Additionally, control room indication is provided to alert the operator whenever an air lock door interlock-mechanism is defeated.

The containment air locks form-part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment-leakage rate within limit in the event of a DBA.

Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the safety analysis. SR 3.6.2.1 leakage rate requirements are in conformance with 10 CFR 50, Appendix J, Option B (Ref. 1),

as modified by approved exemptions.

(continued)

SAN ON0FRE--UNIT 3 B 3.6-5

Containment Air Locks B 3.6.2 BASES (continued)

APPLICABLE For atmospheric containment, the DBAs that result in a SAFETY ANALYSES release of radioactive material within containment are a loss of coolant accident (LOCA), a main steam line break (MSLB) and a control elemen+. assembly'(CEA) ejection accident (Ref. 2).

In the analysis of each of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage.

The containment was designed with an allowable leakage rate of 0.10% of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix J, Option B (Ref. 1), as the maximum allowable containment leakage rate at the calculated peak containment internal pressure, P.

(56.6 asig) following a design basis MSLB (Ref. 3).

This allowa)le leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air lock.

The containment air locks satisfy Criterion 3 of the NRC Policy Statement.

LC0 Each containment air lock forms ) art of the containment pressure boundary. As part of tie containment pressure boundary, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. -Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event.

Each air lock is required to be OPERABLE.

For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The door seals and sealing surface are considered a part of the air lock.

The interlock allows only one air lock door of an air lock to be opened at one time.

This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.

Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into or exit from containment.

V (continued)

SAN ON0FRE--UNIT 3 8 3.6-6

Containment Air Locks B 3.6.2 BASES SURVEILLANCE ER 3.6.2_1 REQUIREMENTS' the Containment Leakage Rate Testing Program.

This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is as specified in the Containment Leakage Rate Testing Program.

The SR has been modified by two Notes.

Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of which is applicable to SR 3.6.1.1.

This ensures that air l

l lock leakage is properly accounted for in determining the

]

combined Type B and C containment leakage rate.

l SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum ex)ected post accident containment pressure, closure of eitler door will support containment OPERABILITY. Thus, the door interlock feature supports 1

containment OPERABILITY while the air lock is being used for personnel transit into and out of containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given (continued)

SAN ON0FRE--UNIT 3 B 3.6-11

f~

Containment Air Locks B 3.6.2 BASES SURVEILLANCE SR 3.6.2.2 (continued)

REQUIREMENTS i

that.the interlock mechanism is only challenged when l

containment is entered, Note 1 specifies that this test is only required to be performed upon entering containment but is not required more frequently than every.184 days.

The j

second note states that SR 3.0.4 is not applicable.

The 184 day Frequency is based on engineering judgment and is considered adequate.in view of other indications of door and interlock mechanism status available to operations personnel.

REFERENCES 1.

10 CFR 50, Appendix J, Option B.

l 2.

UFSAR, Section 15.1, 15.4.

3.

UFSAR, Section 6.2.

SAN ON0FRE--UNIT 3 8 3.6-12 L: -

i Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.5 REQUIREMENTS (continued)

Verifying that the isolation time of each power operated and automatic containment isolation valve is within limits is required to demonstrate OPERABILITY..The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program.

4 SR 3.6.3.6 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B (Ref. 5), is required to l

ensure OPERABILITY. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types.

Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of Generic Issue B-20, " Containment Leakage Due to Seal Deterioration" (Ref.3).

Additionally, this SR must be performed within 92 days after opening the valve.

The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valvethathasnotbeenopened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

A Note to this SR requires the results to be evaluated against the acceptance criteria of SR 3.6.1.1.

This ensures that excessive containment purge valve leakage is properly accounted for in determining the overall containment leakage rate to verify containment OPERABILITY, (continued)

SAN ON0FRE--UNIT 3 B 3.6-25

Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.7 REQUIREMENTS (continued)

The containment isolation valves covered by this SR are required to be demonstrated OPERABLE at the indicated frequency.This SR is modified by two notes. Note 1 specifies that the provisions of the Inservice Testing Program are not applicable when the valves are secured open.

The second note indicates that SR 3.0.4 is not applicable.

SR 3.6.3.8 Automatic containment isolation valves close on an actuation signal to prevent leakage of radioactive material from containment following a DBA.

This SR ensures each automatic containment isolation valve will actuate to its isolation position on an actuation signal.

The 24 month Frequency was

' developed considering it is prudent that this SR be performed only during a unit outage, since isolation of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. Operating experience has shown that these components usually pass this SR wnen performed on the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint, j

REFERENCES 1.

SONGS Units 2 and 3 UFSAR, Section 6.2.

2.

SONGS Units 2 and 3 UFSAR, Section 6.

3.

Generic Issue B-20.

4.

Generic Issue B-24.

5.

10 CFR 50, Appendix J, Option B.

l SAN ON0FRE--UNIT 3 B 3.6-26

Containment Penetrations B 3.9.3 8 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BA5 ES --

l BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will.be restricted from escaping to the environment when the-LC0 requirements are met.

In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LC0 3.6.1, " Containment."

In MODE 6, the potential for containment. aressurization as a result of an accident is not likely; t1erefore, requirements to isolate the containment from the outside atmosphere can be less stringent.

The LC0 requirements are referred to as

" containment closure" rather than " containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed.

Since there is no potential for containment pressurization, the Appendix J, Option B leakage criteria and tests are not required.

l The containment serves to contain fission p_roduct radioactivity that may be released from the reactor core

.following an accident, such that offsite radiation expos'ures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During COllE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LC0 be approximately equally spaced.

The' containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LC0 3.6.2, " Containment Air Locks."

Each air lock has a door at both ends.

The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

SAN ON0FRE--UNIT 3 8 3.9-9 i-

. _ _ _ _ _ _ _ _. -.

ML20216B620

Text

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