Text

Attachment 1, Volume 10, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.7, Plant Systems
	ML11251A103
Person / Time
Site:	San Onofre
Issue date:	07/29/2011
From:	; Edison International Co, Southern California Edison Co
To:	; Office of Nuclear Reactor Regulation
References
	NUREG-1432, Rev. 3.0
	Download: ML11251A103 (485)
	v • d • e

ATTACHMENT 1 VOLUME 10 SAN ONOFRE NUCLEAR GENERATING STATION

IMPROVED TECHNICAL SPECIFICATIONS CONVERSION

ITS SECTION 3.7 PLANT SYSTEMS

LIST OF ATTACHMENTS

1. ITS 3.7.1 - MAIN STEAM SAFETY VALVES

2. ITS 3.7.2 - MAIN STEAM ISOLATION VALVES

3. ITS 3.7.3 - MAIN FEEDWATER ISOLATION VALVES

4. ITS 3.7.4 - AT MOSPHERIC DUMP VALVES

5. ITS 3.7.5 - AUXIL IARY FEEDWATER SYSTEM

6. ITS 3.7.6 - CONDENSATE STORAGE TANKS

7. ITS 3.7.7 - COMPON ENT COOLING WATER SYSTEM

8. ITS 3.7.8 - SALT WATER COOLING SYSTEM 9. ITS 3.7.10 - EMERGENCY CHILLED WATER 10. ITS 3.7.11 - CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM 11. ITS 3.7.12 - CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM 12. ITS 3.7.16 - FUEL STORAGE POOL WATER LEVEL 13. ITS 3.7.17 - FUEL STORAG E POOL BORON CONCENTRATION 14. ITS 3.7.18 - SPENT FUEL ASSEMBLY STORAGE 15. ITS 3.7.19 - SECOND ARY SPECIFIC ACTIVITY 16. ISTS SPECIFIC ATIONS NOT USED

NOTE: There is no ITS 3.7.9, 3.7.13, 3.7.14, or 3.7.15 ATTACHMENT 1 ITS 3.7.1, MAIN STEAM SAFETY VALVES

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

MSSVs 3.7.1 ITS3.7 PLANT SYSTEMS3.7.1 Main Steam Safety Valves (MSSVs)LCO 3.7.1The MSSVs shall be OPERABLE as specified in Table 3.7.1-1and Table 3.7.1-2.APPLICABILITY:MODES 1, 2, and 3.

ACTIONS-------------------------------------NOTE-------------------------------------Separate Condition entry is allowed for each MSSV.

CONDITIONREQUIRED ACTIONCOMPLETION TIMEA.Two to seven requiredMSSVs per SGinoperable.A.1Reduce power to lessthan or equal to the applicable % RTP listed in Table 3.7.1-1.ANDA.2Reduce the LinearPower Level High tripsetpoint in accordance with Table 3.7.1-1.4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s36 hoursB.Required Action andassociated CompletionTime not met.OREight or more requiredMSSVs per SGinoperaple

.B.1Be in MODE 3.ANDB.2Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hoursLCO 3.7.1ApplicabilityACTIONS NoteACTION AACTION BOne or moresteam generatorswith less than two OneOPERABLEA01A02A02SAN ONOFRE--UNIT 23.7-1Amendment No. 212 MSSVs 3.7.1 ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.1.1-------------------NOTE--------------------Only required to be performed in MODES 1 and 2.

Verify each required MSSV lift setpointwithin limits per Table 3.7.1-2 in accordance with the Inservice Testing Program.In accordance with the Inservice Testing Program SR 3.7.1.1Following testing, lift settings shall be within + 1%.A01A03SAN ONOFRE--UNIT 23.7-2Amendment No. 127 MSSVs 3.7.1 ITS Table 3.7.1-1 (page 1 of 1)Maximum Allowable Power Level versus Inoperable MSSVsNUMBER OF INOPERABLEMSSVs PER STEAM GENERATOR MAXIMUMALLOWABLE POWER(% RTP)MAXIMUMALLOWABLELINEAR POWERLEVEL HIGH TRIP(% RTP)2 3 45 to 79556 46MODE 395 56 46Not applicableTable 3.7.1-1OPERABLE Main Steam Safety Valvesand Linear Power Level - High Trip Setpoint MINIMUMREQUIRED OPERABLE

-SETPOINT 7 8 6 5 40 (i.e., 100)111 3 20 (i.e., MODE 3) 0 (i.e., MODE 3)

NA NA NAA01A02SAN ONOFRE--UNIT 23.7-3Amendment No. 212 MSSVs 3.7.1 ITSTable 3.7.1-2 (page 1 of 1)Main Steam Safety Valves (Lift Settings)VALVE NUMBERLIFT SETTING*SteamGenerator#1SteamGenerator#2(psig)2PSV-8401 2PSV-8402 2PSV-8403 2PSV-8404 2PSV-8405 2PSV-8406 2PSV-8407 2PSV-8408 2PSV-8409 2PSV-8410 2PSV-8411 2PSV-8412 2PSV-8413 2PSV-8414 2PSV-8415 2PSV-8416 2PSV-8417 2PSV-8418 1085 10921099 1106 1113 1120 1127 1134 1140*The lift setting pressure shall correspond to ambient conditions of thevalve at nominal operating temperature and pressure. Each MSSV has anas-found tolerance of +2%/-3%. Following testing according to TechnicalSpecification 5.5.2.10, MSSVs will be set within +/-1% of the specifiedlift setpoint.Table 3.7.1-2SR 3.7.1.1lift setting shallA01A04LA01A03SAN ONOFRE--UNIT 23.7-4Amendment No. 212 MSSVs 3.7.1 ITS3.7 PLANT SYSTEMS3.7.1 Main Steam Safety Valves (MSSVs)LCO 3.7.1The MSSVs shall be OPERABLE as specified in Table 3.7.1-1and Table 3.7.1-2.APPLICABILITY:MODES 1, 2, and 3.

ACTIONS-------------------------------------NOTE-------------------------------------Separate Condition entry is allowed for each MSSV.

CONDITIONREQUIRED ACTIONCOMPLETION TIMEA.Two to seven requiredMSSVs per SGinoperable.A.1Reduce power to lessthan or equal to the applicable % RTP listed in Table 3.7.1-1.ANDA.2Reduce the LinearPower Level High tripsetpoint in accordance with Table 3.7.1-1.4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s36 hoursB.Required Action andassociated CompletionTime not met.OREight or more requiredMSSVs per SGinoperaple

.B.1Be in MODE 3.ANDB.2Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hoursLCO 3.7.1ApplicabilityACTIONS NoteACTION AACTION BOne or moresteam generatorswith less than two OneOPERABLEA01A02A02SAN ONOFRE--UNIT 33.7-1Amendment No. 204 MSSVs 3.7.1 ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.1.1-------------------NOTE--------------------Only required to be performed in MODES 1 and 2.

Verify each required MSSV lift setpointwithin limits per Table 3.7.1-2 in accordance with the Inservice Testing Program.In accordance with the Inservice Testing Program SR 3.7.1.1Following testing, lift settings shall be within + 1%.A01A03SAN ONOFRE--UNIT 33.7-2Amendment No. 116 MSSVs 3.7.1 ITS Table 3.7.1-1 (page 1 of 1)Maximum Allowable Power Level versus Inoperable MSSVsNUMBER OF INOPERABLEMSSVs PER STEAM GENERATOR MAXIMUMALLOWABLE POWER(% RTP)MAXIMUMALLOWABLELINEAR POWERLEVEL HIGH TRIP(% RTP)2 3 45 to 79556 46MODE 395 56 46Not applicableTable 3.7.1-1OPERABLE Main Steam Safety Valvesand Linear Power Level - High Trip Setpoint MINIMUMREQUIRED OPERABLE

-SETPOINT 7 8 6 5 40 (i.e., 100)111 3 2 NA NA NA0 (i.e., MODE 3) 0 (i.e., MODE 3)A01A02SAN ONOFRE--UNIT 33.7-3Amendment No. 204 MSSVs 3.7.1 ITSTable 3.7.1-2 (page 1 of 1)Main Steam Safety Valves (Lift Settings)VALVE NUMBERLIFT SETTING*Steam Generator#1Steam Generator#2(psig)3PSV-8401 3PSV-8402 3PSV-8403 3PSV-8404 3PSV-8405 3PSV-8406 3PSV-8407 3PSV-8408 3PSV-8409 3PSV-8410 3PSV-8411 3PSV-8412 3PSV-8413 3PSV-8414 3PSV-8415 3PSV-8416 3PSV-8417 3PSV-8418 1085 10921099 1106 1113 1120 1127 1134 1140*The lift setting pressure shall correspond to ambient conditions of thevalve at nominal operating temperature and pressure. Each MSSV has anas-found tolerance of +2%/-3%. Following testing according to TechnicalSpecification 5.5.2.10, MSSVs will be set within +/-1% of the specifiedlift setpoint.Table 3.7.1-2SR 3.7.1.1lift setting shallA01A04LA01A03SAN ONOFRE--UNIT 33.7-4Amendment No. 204 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 1 of 3 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

A02 CTS 3.7.1 Condition A is for the condition when two to seven required MSSVs per SG are inoperable. The second condition in CTS 3.7.1 Condition B is for the condition when eight or more required MSSVs per SG are inoperable. CTS Table 3.7.1-1 contains the maximum allowable Linear Power Level High trip and maximum allowable power for a corresponding number of inoperable MSSVs per Steam Generator (SG). The Table only provides values when 2 or more MSSV's are inoperable. No actions are required when one MSSV is inoperable.

ITS 3.7.1 ACTION A is for the Condition when one or more required MSSVs are inoperable and the second condition in Condition B is for the condition when one or more steam generators with less than two MSSVs that are OPERABLE. ITS Table 3.7.1-1 contains the maximum allowable Linear Power Level - High Trip Setpoint and the maximum power for a corresponding minimum number of MSSVs per SG required OPERABLE. This changes the CTS wording of Condition A, the second condition of Condition B, and Table 3.7.1-1. This also changes the CTS by providing the maximum power and trip setpoint when all required MSSVs per SG are OPERABLE (i.e., when 8 are OPERABLE).

The CTS 3.7.1 wording in Condition A, the second condition of Condition B, and Table 3.7.1-1 are being changed to be consistent with the wording in the ISTS without changing how the Condition or Table is applied. The major change in wording to note is that the Table will now list the minimum number of MSSVs per SG required to be OPERABLE versus the Number of Inoperable MSSVs per SG; however the corresponding maximum power allowed and the Linear Power Level

- High Trip Setpoint requirements are not being changed. Specifically, SONGS Units 2 and 3 have nine MSSVs per SG. CTS Table 3.7.1-1 only provides limits when two of the MSSVs per SG are inoperable, and CTS 3.7.1 Condition A is entered when two MSSVs per SG are inoperable. Thus, no power reduction is required until 2 of the 9 MSSVs per SG are inoperable. ITS Table 3.7.1-1 specifies that 8 MSSVs per SG are the minimum required to be OPERABLE; however, the maximum specified power level in this condition is 100% RTP.

Power reduction is only required when there are 7 MSSVs OPERABLE. ITS 3.7.1 Condition A also states that it is entered when one or more required MSSVs are inoperable; thus it is entered when there are less than 8 OPERABLE MSSVs per SG (i.e., 2 or more total MSSVs are inoperable). ITS Table 3.7.1-1 specifies when the minimum number of MSSVs is between 4 and 2, the maximum power is 0% which is MODE 3. This is consistent with the CTS requirements. Condition B is for the case when there are less than two MSSVs OPERABLE per steam generator. This is also consistent with the CTS.

DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 2 of 3 Therefore, this change does not affect the actions taken when MSSVs are inoperable and is only an editorial change to be consistent with the ISTS wording preference. This change is designated as Administrative because wording is being changed without altering the application of the CTS.

A03 CTS SR 3.7.1.1 requires verification that each required MSSV lift setpoint is within limits per Table 3.7.1-2 in accordance with the Inservice Testing Program.

CTS Table 3.7.1-2 contains a footnote for the lift settings column that requires lift settings to be set, following testing per CTS 5.5.2.10, the IST Program, within +/-

1% of the values listed in the table. ITS Table 3.7.1-2 does not contain a similar footnote. However, ITS SR 3.7.1.1 requires verification that each required MSSV lift setpoint is per the values in Table 3.7.1-2 in accordance with the Inservice Testing Program and requires that following testing, the lift settings shall be within +/- 1% of the lift setting values listed in the table. This changes the CTS by moving the requirement for the lift settings to be set within +/- 1% of the lift setting values in the table from a footnote in CTS Table 3.7.1-2 to ITS SR 3.7.1.1. In addition, the portion of the footnote which references Specification 5.5.2.10 is being deleted.

This change moves the requirement for the lift setting to be set within +/- 1% from CTS Table 3.7.1-2 to ITS SR 3.7.1.1 and deletes the reference to Specification 5.5.2.10. This change is acceptable because the location of the lift setting as left tolerance requirements is more appropriate for the SR. In addition the reference to Specification 5.5.2.10 (Inservice Testing Program) is not required to ensure the requirement is met. The requirement that the lift setting be within +/- 1% is included in SR 3.7.1.1 and will continue to be required by the IST program. This change does not change the performance of the SR, but more clearly identifies the SR requirements. This change is designated as administrative because this change more clearly identifies the requirement without altering the Surveillance.

A04 CTS Table 3.7.1-2 provides the MSSV valve numbers and lift settings. ITS Table 3.7.1-2 includes the same information, except the unit designators for the valve numbers are not included. This changes the CTS by deleting the unit designator from each of the MSSV valve numbers.

The purpose of CTS Table 3.7.1-2 is to provide the lift setting for each MSSV.

The unit designators are being deleted since SONGS will have a common Technical Specification once this amendment is approved. The valve numbers and the associated lift settings for each valve are the same for the two units.

Therefore, unit designators are not necessary to identify differences between the two units, and this information has been deleted from the Technical Specifications. This change is designated as administrative because the change does not technically alter the Specifications.

MORE RESTRICTIVE CHANGES

None DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 3 of 3 RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.7.1-2 contains a footnote for the Lift Settings Column which in part states the lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. ITS Table 3.7.1-2 does not contain this footnote. This changes the CTS by moving this detail to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.7.1 still retains a requirement for the valves to be OPERABLE. Under the definition of OPERABILITY, the MSSVs must be capable of lifting at the assumed conditions, which includes the ambient operating conditions of the MSSVs themselves. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being moved from the Technical Specifications to the ITS Bases.

LESS RESTRICTIVE CHANGES None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

MSSVs 3.7.1 CEOG STS 3.7.1-1 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX 1U2/U3 CTS 3.7 PLANT SYSTEMS

3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTE----------------------------------------------------------- Separate Condition entry is allowed for each MSSV. -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more required MSSVs inoperable.

A.1 Reduce power to less than or equal to the applicable

% RTP listed in Table 3.7.1-1.

AND A.2 Reduce the

[variable overpower trip - high]

setpoint [ceiling] in accordance with Table 3.7.1-1.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B. Required Action and associated Completion Time not met.

OR One or more steam generators with less

than [two] MSSVs OPERABLE.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

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

[12] hours Linear Power Level - High trip LCO 3.7.1 A pplicability A CTIONS Note A CTION A A CTION B 2 2 2 MSSVs 3.7.1 CEOG STS 3.7.1-2 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX 1U2/U3 CTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 -------------------------------NOTE------------------------------ Only required to be performed in MODES 1 and 2. ---------------------------------------------------------------------

Verify each required MSSV lift setpoint per Table 3.7.1-2 in accordance with the Inservice Testing Program. Following testing, lift settings shall be within +

1%.

In accordance

with the Inservice Testing Program SR 3.7.1.1, Table 3.7.1-2 footnote

MSSVs 3.7.1 CEOG STS 3.7.1-3 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX 1U2/U3 CTS Table 3.7.1-1 (page 1 of 1)

[Variable Overpower Trip] Setpoint versus OPERABLE Main Steam Safety Valves MINIMUM NUMBER OF MSSVs PER STEAM GENERATOR REQUIRED OPERABLE

MAXIMUM POWER (% RTP)

MAXIMUM ALLOWABLE [VARIABLE OVERPOWER TRIP] SETPOINT

([CEILING]

% RTP) [8] [ ] [ ] [7] [ ] [ ] [6] [ ] [ ] [5] [ ] [ ] [4] [ ] [ ] [3] [ ] [ ] [2] [ ] [ ]

100 111 95 56 46 95 56 46 Maximum Power Level and Linear Power Level- High LINEAR POWER LEVEL - HIGH Table 3.7.1-1 2 2 20 (i.e., MODE 3)0 (i.e., MODE 3)0 (i.e., MODE 3)

NA NA NA MSSVs 3.7.1 CEOG STS 3.7.1-4 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX 1U2/U3 CTS Table 3.7.1-2 (page 1 of 1) Main Steam Safety Valve Lift Settings VALVE NUMBER LIFT SETTING (psig +/- [3]%) Steam Generator #1 Steam Generator #2

[ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ]

+ 2% / -

INSERT 1Table 3.7.1-2 2 1 3.7.1 Insert Page 3.7.1-4 INSERT 1 PSV-8401 PSV-8410 1085 PSV-8402 PSV-8411 1092 PSV-8403 PSV-8412 1099 PSV-8404 PSV-8413 1106 PSV-8405 PSV-8414 1113 PSV-8406 PSV-8415 1120 PSV-8407 PSV-8416 1127 PSV-8408 PSV-8417 1134 PSV-8409 PSV-8418 1140

Table 3.7.1-2 U2/U3 CTS 2 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

MSSVs B 3.7.1 CEOG STS B 3.7.1-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1B 3.7 PLANT SYSTEMS

B 3.7.1 Main Steam Safety Valves (MSSVs)

BASES BACKGROUND The primary purpose of the MSSVs is to provide overpressure protection for the secondary system. The MSSVs also provide protection against overpressurizing the reactor coolant pressure boundary (RCPB) by providing a heat sink for the removal of energy from the Reactor Coolant System (RCS) if the preferred heat sink, provided by the Condenser and Circulating Water System, is not available.

Eight MSSVs are located on each main steam header, outside containment, upstream of the main steam isolation valves, as described in the FSAR, Section [5.2] (Ref. 1). The MSSV rated capacity passes the full steam flow at 102% RTP (100% + 2% for instrument error) with the

valves full open. This meets the requirements of the ASME Code,Section III (Ref. 2). The MSSV design includes staggered setpoints, according to Table 3.7.1-1, in the accompanying LCO, so that only the number of valves needed will actuate. Staggered setpoints reduce the potential for valve chattering because of insufficient steam pressure to fully open all valves following a turbine reactor trip.

APPLICABLE The design basis for the MSSVs comes from Reference 2. The MSSV's SAFETY purpose is to limit secondary system pressure to 110% of design ANALYSES pressure when passing 100% of design steam flow. This design basis is sufficient to cope with any anticipated operational occurrence (AOO) or accident considered in the Design Basis Accident (DBA) and transient analysis.

The events that challenge the MSSV relieving capacity, and thus RCS pressure, are those characterized as decreased heat removal events, and are presented in the FSAR, Section

[15.2] (Ref. 3). Of these, the full power loss of condenser vacuum (LOCV) event is the limiting AOO. An LOCV isolates the turbine and condenser, and terminates normal feedwater flow to the steam generators. Before delivery of auxiliary feedwater to the steam generators, RCS pressure reaches 2630 psig. This peak pressure is

< 110% of the design pressure of 2500 psig , but high enough to actuate the pressurizer safety valves. The maximum relieving rate during the LOCV event is 2.5 E6 lb/hour, which is less than the rated capacity of two MSSVs. Nine 10.3.2 must have sufficient capacity to limit the secondary system pressure to 110% of the design pressure.

U U 2750 psiapsia the 2 1 1 2 5within MSSVs B 3.7.1 CEOG STS B 3.7.1-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABLE SAFETY ANALYSES (continued)

The limiting accident for peak RCS pressure is the full power feedwater line break (FWLB), inside containment, with the failure of the backflow check valve in the feedwater line from the affected steam generator.

Water from the affected steam generator is assumed to be lost through the break with minimal additional heat transfer from the RCS. With heat removal limited to the unaffected steam generator, the reduced heat transfer causes an increase in RCS temperature, and the resulting RCS fluid expansion causes an increase in pressure. The RCS pressure increases to 2730 psig, with the pressurizer safety valves providing relief capacity. The maximum relieving rate of the MSSVs during the FWLB event is 2.5 E6 lb/hour, which is less than the rated capacity of two MSSVs.

Using conservative analysis assumptions, a small range of FWLB sizes less than a full double ended guillotine break produce an RCS pressure of 2765 psig for a period of 20 seconds; exceeding 110% (2750 psig) of design pressure. This is considered acceptable as RCS pressure is still well below 120% of design pressure where deformation may occur. The probability of this event is in the range of 4 E-6/year.

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

LCO This LCO requires all MSSVs to be OPERABLE in compliance with Reference 2, even though this is not a requirement of the DBA analysis. This is because operation with less than the full number of MSSVs requires limitations on allowable THERMAL POWER (to meet Reference 2 requirements), and adjustment to the Reactor Protecti on System trip setpoints. These limitations are according to those shown in Table 3.7.1-1, Required Action A.1, and Required Action A.2 in the accompanying LCO. An MSSV is considered inoperable if it fails to open upon demand.

The OPERABILITY of the MSSVs is defined as the ability to open within the setpoint tolerances, relieve steam generator overpressure, and reseat when pressure has been reduced. The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordance with the Inservice Testing Program.

The lift settings, according to Table 3.7.1-2 in the accompanying LCO, correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This LCO provides assurance that the MSSVs will perform their designed safety function to mitigate the consequences of accidents that could result in a challenge to the RCPB. as specified in Tables 3.7.1-1 and 3.7.1-2. The LCO is met when eight of the nine MSSVs per steam generator are OPERABLE. Operation with less than the required number of MSSVs per steam generator OPERABLE ve 1 1 1 4 MSSVs B 3.7.1 CEOG STS B 3.7.1-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABILITY In MODE 1, a minimum of two MSSVs per steam generator are required to be OPERABLE, according to Table 3.7.1-1 in the accompanying LCO, which is limiting and bounds all lower MODES. In MODES 2 and 3, both the ASME Code and the accident analysis require only one MSSV per steam generator to provide overpressure protection.

In MODES 4 and 5, there are no credible transients requiring the MSSVs.

The steam generators are not normally used for heat removal in MODES 5 and 6, and thus cannot be overpressurized; there is no requirement for the MSSVs to be OPERABLE in these MODES.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each MSSV.

A.1 and A.2

An alternative to restoring the inoperable MSSV(s) to OPERABLE status is to reduce power so that the available MSSV relieving capacity meets Code requirements for the power level. Operation may continue provided the allowable THERMAL POWER is equal to the product of: 1) the ratio of the number of MSSVs available per steam generator to the total number of MSSVs per steam generator, and 2) the ratio of the available relieving capacity to total steam flow, multiplied by 100%.

Allowable THERMAL POWER = (8 - N) x 109.2 8

With one or more MSSVs inoperable, the ceiling on the variable overpower trip is reduced to an amount over the allowable THERMAL POWER equal to the band given for this trip, according to Table 3.7.1-1 in the accompanying LCO.

SP = Allowable THERMAL POWER + 9.8 where:

SP = Reduced reactor trip setpoint in percent RTP. This is a ratio of the available relieving capacity over the total steam

flow at rated power.

8 = Total number of MSSVs per steam generator.

N = Number of inoperable MSSVs on the steam generator with the greatest number of inoperable valves.

fiveINSERT 1 required Linear Power Level - High trip setpoint INSERT 2 4 1 1 5 4 B 3.7.1 Insert Page B 3.7.1-3 INSERT 1 THERMAL POWER is limited to the relief capacity of the remaining MSSVs. This is accomplished by restricting THERMAL POWER so that the energy transfer to the most limiting Steam Generator is not greater than the available relief capacity in that Steam Generator.

Operation at or below the maximum power will ensure the design overpressure limits will not be exceeded.

INSERT 2 . The reduced reactor trip allowable values are based on a detailed analysis of the Loss of Condenser Vacuum with a Concurrent Single Failure event (Ref. 3). This analysis considered the concerns identified in NRC Information Notice 94-60 (Ref. 4).

1 1 MSSVs B 3.7.1 CEOG STS B 3.7.1-4 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

ACTIONS (continued)

109.2= Ratio of MSSV relieving capacity at 110% steam generator design pressure to calculated steam flow rate at 100% RTP + 2% instrument uncertainty expressed as a percentage (see text above).

9.8 = Band between the maximum THERMAL POWER and the variable overpower trip setpoint ceiling (Table 3.7.1-1).

The operator should limit the maximum steady state power level to some value slightly below this setpoint to avoid an inadvertent overpower trip.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for Required Action A.1 is a reasonable time period to reduce power level and is based on the low probability of an event occurring during this period that would require activation of the MSSVs. An additional 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months is allowed in Required Action A.2 to reduce the setpoints. The Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for Required Action A.2 is based on a reasonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in steam generator overpressure during this period.

B.1 and B.2

If the MSSVs cannot be restored to OPERABLE status in the associated Completion Time, or if one or more steam generators have less than two MSSVs OPERABLE, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

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

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoints in accordance with the Inservice Testing Program. The ASME Code (Ref.

4), requires that safety and relief valve tests be performed in accordance with ANSI/ASME OM-1-1987 (Ref. 5). According to Reference 5, the following tests are required for MSSVs:

Code, 1998 Edition through 2000 Addenda, Appendix I - Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants 5 6 1 2 1 MSSVs B 3.7.1 CEOG STS B 3.7.1-5 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX BASES

SURVEILLANCE REQUIREMENTS (continued)

a. Visual examination

,

b. Seat tightness determination

,

c. Setpoint pressure determination (lift setting)

, d. Compliance with owner's seat tightness criteria, and e. Verification of the balancing device integrity on balanced valves.

The ANSI/ASME Standard requires that all valves be tested every 5 years, and a minimum of 20% of the valves be tested every 24 months.

The ASME Code specifies the activities and frequencies necessary to satisfy the requirements. Table 3.7.1-2 allows a

+ [3]% setpoint tolerance for OPERABILITY; however, the valves are reset to + 1% during the Surveillance to allow for drift.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This is to allow testing of the MSSVs at hot conditions. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure.

REFERENCES 1. FSAR, Section

[5.2].

2. ASME, Boiler and Pressure Vessel Code,Section III, Article NC-7000, Class 2 Components.

3. FSAR, Section [15.2].

4. ASME Code for Operation and Maintenance of Nuclear Power Plants.

5. ANSI/ASME OM-1-1987. ;;; and . U U 10.3.2ASME OM Code, 1998 Edition through 2000 Addenda, Appendix I - Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants 5 6 4. NRC Information Notice 94-60. ASME OM Code + 2% / - 3%

3 4 2 1 1 3 1 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1 BASES, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. Changes are made to use correct punctuation, correct typographical errors or to make corrections consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

4. The ISTS Tables were modified to reflect SONGS specific requirements for MSSV Operability and; therefore, the ISTS Bases was also revised to reflect the changes made. 5. The Number for the Table in the ISTS Bases (ISTS Table 3.7.1-1) which references the MSSV staggered setpoints is actually Table 3.7.1-2 in the ISTS Specifications and in the SONGS Units 2 and 3 ITS Bases. Also, the term required was added to the ISTS Bases where necessary to be consistent with the ISTS.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES San Onofre Unit 2 and 3 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 2 ITS 3.7.2, MAIN STEAM ISOLATION VALVES

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

MSIVs3.7.2ITS3.7 PLANT SYSTEMS3.7.2 Main Steam Isolation Valves (MSIVs)LCO 3.7.2Two MSIVs shall be OPERABLE.

APPLICABILITY:MODE 1,MODES 2 and 3 except when all MSIVs are closed anddeactivated.ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIMEA.One MSIV inoperable inMODE 1.A.1Restore MSIV toOPERABLE status.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sB.Required Action andAssociated Completion Time of Condition A not met.B.1Be in MODE 2.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months sC.---------NOTE---------Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.C.1Close MSIV.ANDC.2Verify MSIV isclosed.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sOnce per 7 daysD.Required Action andassociated CompletionTime of Condition C not met.D.1Be in MODE 3.ANDD.2Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hoursLCO 3.7.2ApplicabilityACTION AACTION BACTION CACTION DA01SAN ONOFRE--UNIT 23.7-5Amendment No. 127 MSIVs3.7.2ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.2.1Verify closure time of each MSIV is

8.0 seconds

.In accordance with the Inservice Testing ProgramSR 3.7.2.1within limitsINSERT 1A01LA01M01SAN ONOFRE--UNIT 23.7-6Amendment No. 127 3.7.2 Insert Page 3.7-6 INSERT 1 SR 3.7.2.2 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

In accordance

with the Surveillance

Frequency

Control Program

SR 3.7.2.2 ITS M01 MSIVs3.7.2ITS3.7 PLANT SYSTEMS3.7.2 Main Steam Isolation Valves (MSIVs)LCO 3.7.2Two MSIVs shall be OPERABLE.

APPLICABILITY:MODE 1,MODES 2 and 3 except when all MSIVs are closed anddeactivated.ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIMEA.One MSIV inoperable inMODE 1.A.1Restore MSIV toOPERABLE status.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sB.Required Action andAssociated Completion Time of Condition A not met.B.1Be in MODE 2.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months sC.---------NOTE---------Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.C.1Close MSIV.ANDC.2Verify MSIV isclosed.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sOnce per 7 daysD.Required Action andassociated CompletionTime of Condition C not met.D.1Be in MODE 3.ANDD.2Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hoursLCO 3.7.2ApplicabilityACTION AACTION BACTION CACTION DA01SAN ONOFRE--UNIT 33.7-5Amendment No. 116 MSIVs3.7.2ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.2.1Verify closure time of each MSIV is

8.0 seconds

.In accordance with the Inservice Testing ProgramSR 3.7.2.1within limitsINSERT 1A01LA01M01SAN ONOFRE--UNIT 33.7-6Amendment No. 116 3.7.2 Insert Page 3.7-6 INSERT 1 SR 3.7.2.2 Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

In accordance

with the Surveillance

Frequency

Control Program

SR 3.7.2.2 ITS M01 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES San Onofre Unit 2 and 3 Page 1 of 2 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

MORE RESTRICTIVE CHANGES M01 CTS 3.7.2 does not include a requirement to verify that each MSIV actuates to the isolation position on an actual or simulated actuation signal. ITS 3.7.2 contains an SR (SR 3.7.2.2) to verify that each MSIV actuates to the isolation position on an actual or simulated actuation signal at a Frequency that will be specified in the Surveillance Frequency Control Program. This changes the CTS

by adding a new Surveillance Requirement.

The purpose of ITS SR 3.7.2.2 is to verify that the MSIVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MSIVs will perform their safety function. The Frequency for this new SR will be specified in the Surveillance Frequency Control Program. The initial Frequency specified will be 24 months, which is consistent with the current SONGS refueling outage Surveillance interval. Any change to this 24 month Frequency will be made in accordance with the Surveillance Frequency Control Program. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that is not included in the CTS.

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Detail for Meeting TS Requirements or Reporting Requirements)

CTS SR 3.7.2.1 requires verification that the closure time of each MSIV is 8.0 seconds. ITS SR 3.7.2.1 requires verification that the closure time of each MSIV is within limits. This changes the CTS by moving the MSIV closure time limit to the Licensee Controlled Specifications (LCS).

The removal of MSIV closure times from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES San Onofre Unit 2 and 3 Page 2 of 2 and safety. The ITS retains the requirement to verify that the isolation time of each MSIV is within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the LCS. The LCS is incorporated by reference into the UFSAR and any changes to the LCS are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES

None

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

MSIVs 3.7.2 CEOG STS 3.7.2-1 Rev. 3.0, 03/31/04 U2/U3 CTS San Onofre -- Draft Amendment XXX 13.7 PLANT SYSTEMS

3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2

[Two] MSIVs shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed

[and de-activated

].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

[8] hours B. Required Action and Associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

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

Separate Condition entry is allowed for each MSIV. ---------------------------------

One or more MSIVs inoperable in MODE 2

or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

[8] hours

Once per 7 days

D. Required Action and associated Completion Time of Condition C not met. D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

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

[12] hours

A pplicability LCO 3.7.2 A CTION A A CTION B A CTION C A CTION D 2 2 2 2 2 MSIVs 3.7.2 CEOG STS 3.7.2-2 Rev. 3.0, 03/31/04 U2/U3 CTS San Onofre -- Draft Amendment XXX 1SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 -------------------------------NOTE------------------------------ Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is [4.6] seconds.

In accordance

with the Inservice Testing Program

SR 3.7.2.2 -------------------------------NOTE------------------------------ Only required to be performed in MODES 1 and 2. ---------------------------------------------------------------------

Verify each MSIV actuates to the isolation position on an actual or simulated actuation signal.

[18] months within limits TSTF-425-AIn accordance with the Surveillance Frequency Control Program SR 3.7.2.1 DOC M01 TSTF-491-A 3 3 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. ISTS SR 3.7.2.1 and SR 3.7.2.2 are modified by a Note which states, "Only required to be performed in MODES 1 and 2." This Note is being deleted for the SONGS Units 2 and 3 ITS. The SONGS Units 2 and 3 valves are pneumatic/hydraulic valves which do not require detailed testing at design operating temperature and pressure, but instead the testing relies on stroke time and detailed calculations/analysis. This change is acceptable because SONGS Units 2 and 3 do not need to be at normal operating temperature and pressure to perform these surveillances, thus SCE normally performs these surveillances in MODES 4, 5, or 6. This change is consistent with SONGS CTS SR 3.7.2.1.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

MSIVs B 3.7.2 CEOG STS B 3.7.2-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1B 3.7 PLANT SYSTEMS

B 3.7.2 Main Steam Isolation Valves (MSIVs)

BASES BACKGROUND The MSIVs isolate steam flow from the secondary side of the steam generators following a high energy line break (HELB). MSIV closure terminates flow from the una ffected (intact) steam generator.

One MSIV is located in each main steam line outside, but close to, containment. The MSIVs are downstream from the main steam safety valves (MSSVs), atmospheric dump valves, and auxiliary feedwater pump turbine steam supplies to prevent their being isolated from the steam generators by MSIV closure. Closing the MSIVs isolates each steam generator from the other, and isolates the turbine, Steam Bypass System, and other auxiliary steam supplies from the steam generators.

The MSIVs close on a m ain s team i solation signal generated by either low steam generator pressure or high containment pressure. The MSIVs fail closed on loss of control or actuation power. The MSIS also actuate s the main feedwater isolation valves (MFIVs) to close. The MSIVs may also be actuated manually.

A description of the MSIVs is found in the FSAR, Section

[10.3] (Ref. 1).

APPLICABLE The design basis of the MSIVs is established by the containment analysis SAFETY for the large steam line break (SLB) inside containment, as discussed in ANALYSES the FSAR, Section

[6.2] (Ref. 2). It is also influenced by the accident analysis of the SLB events presented in the FSAR, Section

[15.1.5] (Ref. 3). The design precludes the blowdown of more than one steam generator, assuming a single active component failure (e.g., the failure of one MSIV to close on demand).

The limiting case for the containment analysis is the hot zero power SLB inside containment with a loss of offsite power following turbine trip, and failure of the MSIV on the affected steam generator to close. At zero power, the steam generator inventory and temperature are at their maximum, maximizing the analyzed mass and energy release to the containment. Due to reverse flow, failure of the MSIV to close contributes to the total release of the additional mass and energy in the steam headers, which are downstream of the other MSIV. With the most reactive rod cluster control assembly assumed stuck in the fully and on Containment Isolation Actuation Signal (CIAS) by U U U element single 1 1 2 1 2 1 3 M S S I (MSIS)6and CIAS MSIVs B 3.7.2 CEOG STS B 3.7.2-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABLE SAFETY ANALYSES (continued)

withdrawn position, there is an increased possibility that the core will become critical and return to power. The core is ultimately shut down by the borated water injection delivered by the Emergency Core Cooling System. Other failures considered are the failure of an MFIV to close, and failure of an emergency diesel generator to start.

The accident analysis compares several different SLB events against different acceptance criteria. The large SLB outside containment upstream of the MSIV is limiting for offsite dose, although a break in this short section of main steam header has a very low probability. The large SLB inside containment at hot zero power is the limiting case for a post trip return to power. The analysis includes scenarios with offsite power available and with a loss of offsite power following turbine trip.

With offsite power available, the reactor coolant pumps continue to circulate coolant through the steam generators, maximizing the Reactor Coolant System (RCS) cooldown. With a loss of offsite power, the response of mitigating systems, such as the high pressure safety injection (HPSI) pumps, is delayed. Significant single failures considered include:

failure of a MSIV to close, failure of an emergency diesel generator, and failure of a HPSI pump.

The MSIVs serve only a safety function and remain open during power operation. These valves operate under the following situations:

a. An HELB inside containment. In order to maximize the mass and energy release into the containment, the analysis assumes that the MSIV in the affected steam generator remains open. For this accident scenario, steam is discharged into containment from both steam generators until closure of the MSIV in the intact steam generator occurs. After MSIV closure, steam is discharged into containment only from the affected steam generator, and from the residual steam in the main steam header downstream of the closed MSIV in the intact loop.

b. A break outside of containment and upstream from the MSIVs. This scenario is not a containment pressurization concern. The uncontrolled blowdown of more than one steam generator must be prevented to limit the potential for uncontrolled RCS cooldown and positive reactivity addition. Closure of the MSIVs isolates the break, and limits the blowdown to a single steam generator. to close 1 MSIVs B 3.7.2 CEOG STS B 3.7.2-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABLE SAFETY ANALYSES (continued)

c. A break downstream of the MSIVs. This type of break will be isolated by the closure of the MSIVs. Events such as increased steam flow through the turbine or the steam bypass valves will also terminate on closure of the MSIVs.

d. A steam generator tube rupture. For this scenario, closure of the MSIV[s] isolates the affected steam generator from the intact steam generator. In addition to minimizing radiological releases, this enables the operator to maintain the pressure of the steam generator

with the ruptured tube below the MSSV setpoints, a necessary step toward isolating the flow through the rupture.

e. The MSIVs are also utilized during other events such as a feedwater line break. These events are less limiting so far as MSIV OPERABILITY is concerned.

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

LCO This LCO requires that the MSIV in each of the

[two] steam lines be OPERABLE. The MSIVs are considered OPERABLE when the isolation times are within limits, and they close on an isolation actuation signal.

This LCO provides assurance that the MSIVs will perform their design safety function to mitigate the consequences of accidents that could result in offsite exposures comparable to the 10 CFR 100 (Ref. 4) limits or the NRC staff approved licensing basis.

APPLICABILITY The MSIVs must be OPERABLE in MODE 1 and in MODES 2 and 3 except when all MSIVs are closed and

[deactivated

]. In these MODES there is significant mass and energy in the RCS and steam generators.

When the MSIVs are closed, they are already performing their safety function.

In MODE 4, the steam generator energy is low; therefore, the MSIVs are not required to be OPERABLE.

In MODES 5 and 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the MSIVs are not required for isolation of potential high energy secondary system pipe breaks in these MODES.

7 2 2 2 10 CFR 50.67 (Ref. 5) limits, as appropriate MSIVs B 3.7.2 CEOG STS B 3.7.2-4 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

ACTIONS A.1 With one MSIV inoperable in MODE 1, time is allowed to restore the component to OPERABLE status. Some repairs can be made to the MSIV with the unit hot. The

[8] hour Completion Time is reasonable, considering the probability of an accident occurring during the time period that would require closure of the MSIVs.

The [8] hour Completion Time is greater than that normally allowed for containment isolation valves because the MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment isolation valves in that the closed system provides an additional means for containment isolation.

B.1 If the MSIV cannot be restored to OPERABLE status within

[8] hours, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Condition C would be entered. The Completion Time is reasonable, based on operating experience, to reach MODE 2, and close the MSIVs in an orderly manner and without challenging unit systems.

C.1 , C.2.1, and C.2.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

The [8] hour Completion Time is consistent with that allowed in Condition A.

Inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

2 2 2 3 2 MSIVs B 3.7.2 CEOG STS B 3.7.2-5 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

ACTIONS (continued)

D.1 and D.2

If the MSIVs cannot be restored to OPERABLE status, or closed, within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

[12] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that the closure time of each MSIV is [4.6] seconds.

The MSIV isolation time is assumed in the accident and containment analyses. This SR is normally performed upon returning the unit to operation following a refueling outage. The MSIVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code (Ref. 5)

, requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

This test is conducted in MODE 3, with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, in order to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency of MSIV testing is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

TSTF-491-AThis SR also verifies the valve closure time is in accordance with the Inservice Testing Program. within the limit given in Reference 6 and is within that INSERT 1 TSTF-425-A 7 2 6prior to MODE 3 during 8 9 8prior to MODE 3 during B 3.7.2 Insert Page B 3.7.2-5 INSERT 1 The Frequency is controlled under the Surveillance Frequency Control Program.

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

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

TSTF-425-A 4 5 MSIVs B 3.7.2 CEOG STS B 3.7.2-6 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES REFERENCES 1. FSAR, Section

[10.3].

2. FSAR, Section

[6.2].

3. FSAR, Section

[15.1.5].

4. 10 CFR 100.11.

5. ASME Code for Operation and Maintenance of Nuclear Power Plants. U U 7 6. Technical Requirements Manual TSTF-491-A 1 2 1Licensee Controlled Specifications.

35. 10 CFR 50.67. 7 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2 BASES, MAIN STEAM ISOLATION VALVES San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. Changes are made to be consistent with the actual Specification.

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

5. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

6. Changes are made to use correct punctuation, correct typographical errors or to make corrections consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

7. The ITS 3.7.2 Bases (LCO Section) is being revised to add reference to 10 CFR 50.67 to reflect that the MSLB event is evaluated using 10 CFR 50.67 for offsite dose limits (SONGS is approved for Alternative Source Term).

8. ISTS SR 3.7.2.1 and 3.7.2.2 Bases (first paragraph) states, "This SR is normally performed upon returning the unit to operation following a refueling outage." This statement will be revised to read, "The SR is normally performed prior to MODE 3 during a refueling outage." This is acceptable because this SR is normally performed at SONGS Units 2 and 3 in MODE 4, 5, or 6, thus using the ISTS wording "following a refueling outage" would not be correct. This change is related to the deletion of the ISTS SR 3.7.2.1 and SR 3.7.2.2 Note, which is justified by JFD 3 for the ITS Markup. This JFD discusses that SONGS Units 2 and 3 valves are pneumatic/hydraulic valves and do not require detailed testing at design operating temperature and pressure. Instead the testing relies on stroke time and detailed calculations/analysis.

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

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES San Onofre Unit 2 and 3 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 3 ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

MFIVs 3.7.3 3.7 PLANT SYSTEMS ITS 3.7.3 Main Feedwater Isolation Valves (MFIVs). LCO 3.7.3Two MFIVs shall be OPERABLE.APPLICABILITY:MODES 1, 2, and 3 except when MFIV is closed and deactivated.

ACTIONS-------------------------------------NOTE-------------------------------------

Separate Condition entry is allowed for each valve.

CONDITIONREQUIRED ACTIONCOMPLETION TIMEA.One or more MFIVs inoperable.A.1Close or isolate inoperable MFIV.

ANDA.2Verify inoperable MFIV valve is closed

or isolated.

7 days Once per 7 days

B.Required Action and associated Completion

Time not met.B.1Be in MODE 3.

ANDB.2Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours LCO 3.7.3 ApplicabilityACTION NoteACTION AACTION B A01SAN ONOFRE--UNIT 23.7-7Amendment No. 127 MFIVs 3.7.3 3.7 PLANT SYSTEMS ITS SURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.3.1Verify the closure time of each MFIV 10 seconds

.In accordance

with the Inservice Testing Program

SR 3.7.3.1 SR 3.7.3.2within limits INSERT 1 A01 LA01 M01SAN ONOFRE--UNIT 23.7-8Amendment No. 127 3.7.3 Insert Page 3.7-8 INSERT 1 SR 3.7.3.2 Verify each MFIV actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance

Frequency

Control Program

SR 3.7.3.2 ITS M01 MFIVs 3.7.3 3.7 PLANT SYSTEMS ITS 3.7.3 Main Feedwater Isolation Valves (MFIVs). LCO 3.7.3Two MFIVs shall be OPERABLE.APPLICABILITY:MODES 1, 2, and 3 except when MFIV is closed and deactivated.

ACTIONS-------------------------------------NOTE-------------------------------------

Separate Condition entry is allowed for each valve.

CONDITIONREQUIRED ACTIONCOMPLETION TIMEA.One or more MFIVs inoperable.A.1Close or isolate inoperable MFIV.

ANDA.2Verify inoperable MFIV valve is closed

or isolated.

7 days Once per 7 days

B.Required Action and associated Completion

Time not met.B.1Be in MODE 3.

ANDB.2Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours LCO 3.7.3 ApplicabilityACTION NoteACTION AACTION B A01SAN ONOFRE--UNIT 33.7-7Amendment No. 116 MFIVs 3.7.3 3.7 PLANT SYSTEMS ITS SURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.3.1Verify the closure time of each MFIV 10 seconds

.In accordance

with the Inservice Testing Program

SR 3.7.3.1 SR 3.7.3.2within limits INSERT 1 A01 LA01 M01SAN ONOFRE--UNIT 33.7-8Amendment No. 116 3.7.3 Insert Page 3.7-8 INSERT 1 SR 3.7.3.2 Verify each MFIV actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance

Frequency

Control Program

SR 3.7.3.2 ITS M01 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

San Onofre Unit 2 and 3 Page 1 of 2 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

MORE RESTRICTIVE CHANGES M01 CTS 3.7.3 does not include a requirement to verify that each MFIV actuates to the isolation position on an actual or simulated actuation signal. ITS 3.7.3 contains an SR (SR 3.7.3.2) to verify that each MFIV actuates to the isolation position on an actual or simulated actuation signal at a Frequency that will be specified in the Surveillance Frequency Control Program. This changes the CTS

by adding a new Surveillance Requirement.

The purpose of ITS SR 3.7.3.2 is to verify that the MFIVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MFIVs will perform their safety function. The Frequency for this new SR will be specified in the Surveillance Frequency Control Program. The initial Frequency specified will be 24 months, which is consistent with the current SONGS refueling outage Surveillance interval. Any change to this 24 month Frequency will be made in accordance with the Surveillance Frequency Control Program. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that is not included in the CTS.

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Detail for Meeting TS Requirements or Reporting Requirements) CTS SR 3.7.3.1 requires verification that the closure time of each MFIV is 10.0 seconds. ITS SR 3.7.3.1 requires verification that the closure time of each MFIV is within limits. This changes the CTS by moving the MFIV closure time limit to the Licensee Controlled Specifications (LCS).

The removal of MFIV closure times from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

San Onofre Unit 2 and 3 Page 2 of 2 and safety. The ITS retains the requirement to verify that the isolation time of each MFIV is within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the LCS. The LCS is incorporated by reference into the UFSAR and any changes to the LCS are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES

None

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

MFIVs [and [MFIV] Bypass Valves]

3.7.3 CEOG STS 3.7.3-1 Rev. 3.0, 03/31/04 U2/U3 CTS San Onofre -- Draft Amendment XXX 1 23.7 PLANT SYSTEMS

3.7.3 Main Feedwater Isolation Valves (MFIVs) [and [MFIV] Bypass Valves]

LCO 3.7.3

[Two] MFIVs [and [MFIV] bypass valves] shall be OPERABLE.

APPLICABILITY: MODES 1, 2, [and 3] except when MFIV

[or [MFIV] bypass valve]

is closed and

[de-activated] or [isolated by a closed manual valve].

ACTIONS

NOTE----------------------------------------------------------- Separate Condition entry is allowed for each valve. -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more MFIVs

[or [MFIV] bypass valves]

inoperable.

A.1 Close or isolate inoperable MFIV [or [MFIV] bypass valve].

AND A.2 Verify inoperable MFIV

[or [MFIV] bypass valve]

is closed or isolated.

[8 or 72] hours

Once per 7 days B. [ [Two] valves in the same flow path inoperable.

B.1 Isolate affected flow path.

AND B.2 Verify inoperable MFIV [or [MFIV] bypass valve] is closed or isolated.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

Once per 7 days ]

C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

[ AND C.2 Be in MODE 4.

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

[12] hours ] 7 da y s B B B LCO 3.7.3 A pplicability A CTION Note A CTION A A CTION B 2 1 2 2 1 3 MFIVs [and [MFIV] Bypass Valves]

3.7.3 CEOG STS 3.7.3-2 Rev. 3.0, 03/31/04 U2/U3 CTS San Onofre -- Draft Amendment XXX 1 2SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the isolation time of each MFIV [and [MFIV]

bypass valve]

is [7] seconds.

In accordance with the Inservice Testing Program

SR 3.7.3.2 Verify each MFIV [and [MFIV] bypass valve]

actuates to the isolation position on an actual or simulated actuation signal.

[18] months TSTF-491-Awithin limits TSTF-425-AIn accordance with the Surveillance Frequency Control Program SR 3.7.3.1 DOC M01 2 2 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. The ISTS 3.7.3 ACTION A Completion Time to close or isolate the inoperable MFIV when one or more MFIVs are inoperable is bracketed with 8 or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months contained within the brackets. This change incorporates 7 days for the SONGS ITS 3.7.3 ACTION A Completion Time to close or isolate the inoperable MFIV when one or more MFIVs are inoperable. The 7 day Completion Time is the value contained in the SONGS CTS and will be adopted in the SONGS ITS. The 7 day Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves, and the low probability of an event occurring during this time period that would require isolation of the MFW flow path.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

MFIVs [and [MFIV] Bypass Valves]

B 3.7.3 CEOG STS B 3.7.3-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 2 1B 3.7 PLANT SYSTEMS

B 3.7.3 Main Feedwater Isolation Valves (MFIVs)

[and [MFIV] Bypass Valves]

BASES BACKGROUND The MFIVs isolate main feedwater (MFW) flow to the secondary side of the steam generators following a high energy line break (HELB). Closure

of the MFIVs and the bypass valves terminates flow to both steam generators, terminating the event for feedwater line breaks (FWLBs) occurring upstream of the MFIVs. The consequences of events occurring in the main steam lines or in the MFW lines downstream of the MFIVs will be mitigated by their closure. Closure of the MFIVs and bypass valves effectively terminates the addition of feedwater to an affected steam generator, limiting the mass and energy release for steam line breaks (SLBs) or FWLBs inside containment, and reducing the cooldown effects

for SLBs.

The MFIVs and bypass valves isolate the nonsafety related portions from the safety related portion of the system. In the event of a secondary side pipe rupture inside containment, the valves limit the quantity of high energy fluid that enters containment through the break, and provide a pressure boundary for the controlled addition of auxiliary feedwater (AFW) to the intact loop.

One MFIV is located on each AFW line, outside, but close to, containment. The MFIVs are located upstream of the AFW injection point so that AFW may be supplied to a steam generator following MFIV closure. The piping volume from the valve to the steam generator must be accounted for in calculating mass and energy releases, and refilled prior to AFW reaching the steam generator following either an SLB or FWLB.

The MFIVs and its bypass valves close on receipt of a main steam isolation signal (MSIS) generated by either low steam generator pressure or high containment pressure. The MSIS also actuate s the main steam isolation valves (MSIVs) to close. The MFIVs and bypass valves may also be actuated manually. In addition to the MFIVs and the bypass valves, a check valve inside containment is available to isolate the feedwater line penetrating containment, and to ensure that the

consequences of events do not exceed the capacity of the containment heat removal systems.

A description of the MFIVs is found in the FSAR, Section

[10.4.7] (Ref. 1).

Mon receipt of a containment isolation actuation signal (CIAS) and CIAS U 2 1 1 1 2 1 1 1 MFIVs [and [MFIV] Bypass Valves]

B 3.7.3 CEOG STS B 3.7.3-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 2 1BASES

APPLICABLE The design basis of the MFIVs is established by the analysis for the large SAFETY SLB. It is also influenced by the accident analysis for the large FWLB.

ANALYSES Closure of the MFIVs and their bypass valves may also be relied on to terminate a steam break for core response analysis and an excess feedwater flow event upon receipt of a MSIS on high steam generator level.

Failure of an MFIV and the bypass valve to close following an SLB, FWLB, or excess feedwater flow event can result in additional mass and energy to the steam generators contributing to cooldown. This failure also results in additional mass and energy releases following an SLB or FWLB event.

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

LCO This LCO ensures that the MFIVs and the bypass valves will isolate MFW flow to the steam generators. Following an FWLB or SLB, these valves will also isolate the nonsafety related portions from the safety related portions of the system. This LCO requires that [two] MFIV s [and [MFIV]

bypass valves] in each feedwater line be OPERABLE. The MFIVs and the bypass valves are considered OPERABLE when the isolation times

are within limits, and are close d on an isolation actuation signal. Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. If an MSIS on high steam generator level is relied on to terminate an excess feedwater flow event, failure to meet the LCO may result in the introduction of water into the main steam lines.

APPLICABILITY The MFIVs and the bypass valves must be OPERABLE whenever there is significant mass and energy in the Reactor Coolant System and steam generators. This ensures that, in the event of an HELB, a single failure cannot result in the blowdown of more than one steam generator.

In MODES 1, 2, and 3, the MFIV [or [MFIV] bypass valves] are required to be OPERABLE, except when they are closed and deactivated or isolated by a closed manual valve, in order to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are closed and

deactivated or isolated by a closed manual valve , they are already performing their safety function.

In MODES 4, 5, and 6, steam generator energy is low. Therefore, the MFIVs and the bypass valves are normally closed since MFW is not

required.

one MSIS and CIAS s 3 1 3 2 3 2 3 3 1 1 low pressure will 3 MFIVs [and [MFIV] Bypass Valves]

B 3.7.3 CEOG STS B 3.7.3-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 2 1BASES

ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each value.

A.1 and A.2

With one MFIV or the bypass valve inoperable, action must be taken to close or isolate the inoperable valves within [8 or 72] hours. When these valves are closed or isolated, they are performing their required safety function (e.g., to isolate the line).

For units with only one MFIV per feedwater line: The [8] hour Completion

Time is reasonable to close the MFIV or its bypass valve, which includes performing a controlled unit shutdown to MODE 2.

The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves, and the low probability of an event occurring during this time period that would require isolation of

the MFW flow paths.

B.1 If more than one MFIV or [MFIV] bypass valve in the same flow path cannot be restored to OPERABLE status, then there may be no redundant system to operate automatically and perform the required safety function. Although the containment can be isolated with the failure of two valves in parallel in the same flow path, the double failure can be an indication of a common mode failure in the valves of this flow path, and as such is treated the same as a loss of the isolation capability of this flow path. Under these conditions, valves in each flow path must be restored to OPERABLE status, closed, or the flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable to close the MFIV or its bypass valve, or otherwise isolate the affected flow path.

Inoperable MFIVs and [MFIV] bypass valves that cannot be restored to OPERABLE status within the Completion Time, but are closed or isolated, must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indi cations available in the control room, and other administrative controls to ensure that these valves are closed or isolated.

s 7 da y s 7 da y or more 3 1 3 3 3 MFIVs [and [MFIV] Bypass Valves]

B 3.7.3 CEOG STS B 3.7.3-4 Rev. 3.1, 12/01/05 2San Onofre -- Draft Revision XXX 1BASES ACTIONS (continued)

C.1 and [C.2]

If the MFIVs and their bypass valves cannot be restored to OPERABLE status, closed, or isolated in the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

[, and in MODE 4 within

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

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR ensures the verification of each MFIV [and [MFIV] bypass valve]

is [7] seconds. The MFIV isolation time is assumed in the accident and containment analyses. This Surveillance is normally performed upon returning the unit to operation following a refueling outage. The MFIVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As these valves are not tested at power, they are exempt from the ASME Code (Ref. 2) requirements during operation in MODES 1 and 2.

The Frequency is in accordance with the Inservice Testing Program.

SR 3.7.3.2

This SR verifies that each MFIV [and [MFIV] bypass valve]

can close on an actual or simulated actuation signal. This Surveillance is normally

performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the

Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section

[10.4.7].

2. ASME Code for Operation and Maintenance of Nuclear Power Plants. B TSTF-491-Awithin the limit given in Reference 2 and is withinthat This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. SR 3 TSTF-491-A 3 2. Technical Requirements Manual TSTF-425-AINSERT 1 U TSTF-425-A 3 2 2 2 1Licensee Controlled Specifications.

1prior to MODE 3 during 6 6 B 3.7.3 Insert Page 3.7.3-4 INSERT 1 The Frequency is controlled under the Surveillance Frequency Control Program.

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

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

TSTF-425-A 4 5 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3 BASES, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

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

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

ITS.

5. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

6. ISTS SR 3.7.3.1 and SR 3.7.3.2 Bases states, "This SR is normally performed upon returning the unit to operation following a refueling outage." This statement will be revised to read, "The SR is normally performed prior to MODE 3 during a refueling outage." This is acceptable because SCE normally performs this test in MODES 4, 5, or 6 and using the ISTS wording "following a refueling outage," would not be correct. This change is acceptable because SONGS Units 2 and 3 valves are pneumatic/hydraulic valves which do not require detailed testing at design operating temperature and pressure, but instead the testing relies on stroke time and detailed calculations/analysis.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

San Onofre Unit 2 and 3 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 4 ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ADVs3.7.4 ITS3.7 PLANT SYSTEMS3.7.4 Atmospheric Dump Valves (ADVs)LCO 3.7.4One ADV per required Steam Generator (SG) shall be OPERABLE.APPLICABILITY:MODES 1, 2, and 3,MODE 4 when steam generator is relied upon for heat removal.ACTIONS CONDITIONREQUIRED ACTIONCOMPLETION TIME A.One required ADV inoperable.

A.1--------NOTE---------LCO 3.0.4 is notapplicable.---------------------Restore ADV toOPERABLE status.72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.Two ADV s inoperable.

B.1Restore one ADV toOPERABLE status.24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sC.Backup nitrogen gassupply system capacity

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one ormore required ADV(s). C.1Restore backupnitrogen gas supplysystem capacity forone or more requiredADV(s). 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)LCO 3.7.4ApplicabilityACTION CACTION DACTIONS A and B line line Cfor reasons other thanCondition A.

required C line D linesfor reasons other thanCondition B.

line DA. One required ADV line inoperable due to backup nitrogen gas supply system capacity

8 hours.

A.1 Restore ADV line to OPERABLE status.

6 daysB. Two required ADV lines inoperable due to backup nitrogen gas supply system capacity

8 hours. B.1 Restore one ADV line to OPERABLE status.

96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months sA01M01M01M02A02M01A02M01A03A02SAN ONOFRE--UNIT 23.7-9Amendment No. 127 ADVs3.7.4 ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIME D.Required Action andassociated CompletionTime of Condition A or B not met.D.1Be in MODE 3.AND D.2Be in MODE 4 withoutreliance upon steam generator for heat removal.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s18 hoursE.Required Action andassociated completiontime of Condition Cnot met.E.1Declare the ADVinoperable.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.4.1Verify the capacity of the backup nitrogensupply system.7 daysSR 3.7.4.2Verify one complete cycle of each ADV. In accordancewith the Inservice Testing Program ACTION ESR 3.7.4.1SR 3.7.4.2In accordance with theSurveillance FrequencyControl Program E Eis > 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sINSERT 1A01A02A02LA01A04M01SAN ONOFRE--UNIT 23.7-10Amendment No. 127 3.7.4 3.7-10 ITS INSERT 1 SR 3.7.4.3 Verify one complete cycle of each ADV block valve.

In accordance with the Surveillance

Frequency

Control Program

SR 3.7.4.3 M01 ADVs3.7.4 ITS3.7 PLANT SYSTEMS3.7.4 Atmospheric Dump Valves (ADVs)LCO 3.7.4One ADV per required Steam Generator (SG) shall be OPERABLE.APPLICABILITY:MODES 1, 2, and 3,MODE 4 when steam generator is relied upon for heat removal.ACTIONS CONDITIONREQUIRED ACTIONCOMPLETION TIME A.One required ADV inoperable.

A.1--------NOTE---------LCO 3.0.4 is notapplicable.---------------------Restore ADV toOPERABLE status.72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.Two ADV s inoperable.

B.1Restore one ADV toOPERABLE status.24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sC.Backup nitrogen gassupply system capacity

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one ormore required ADV(s). C.1Restore backupnitrogen gas supplysystem capacity forone or more requiredADV(s). 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)LCO 3.7.4ApplicabilityACTION CACTION DACTIONS A and B line line Cfor reasons other thanCondition A.

required C line D linesfor reasons other thanCondition B.

line DA. One required ADV line inoperable due to backup nitrogen gas supply system capacity

8 hours.

A.1 Restore ADV line to OPERABLE status.

6 daysB. Two required ADV lines inoperable due to backup nitrogen gas supply systems capacity

8 hours. B.1 Restore one ADV line to OPERABLE status.

96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months sA01M01M01M02A02M01A02M01A03A02SAN ONOFRE--UNIT 33.7-9Amendment No. 116 ADVs3.7.4 ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIME D.Required Action andassociated CompletionTime of Condition A or B not met.D.1Be in MODE 3.AND D.2Be in MODE 4 withoutreliance upon steam generator for heat removal.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s18 hoursE.Required Action andassociated completiontime of Condition Cnot met.E.1Declare the ADVinoperable.ImmediatelySURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.4.1Verify the capacity of the backup nitrogensupply system.7 daysSR 3.7.4.2Verify one complete cycle of each ADV. In accordancewith the Inservice Testing Program ACTION ESR 3.7.4.1SR 3.7.4.2In accordance with theSurveillance FrequencyControl Program E Eis > 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sINSERT 1A01A02A02LA01A04M01SAN ONOFRE--UNIT 33.7-10Amendment No. 116 3.7.4 3.7-10 ITS INSERT 1 SR 3.7.4.3 Verify one complete cycle of each ADV block valve.

In accordance with the Surveillance

Frequency

Control Program

SR 3.7.4.3 M01 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 1 of 6 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

A02 CTS 3.7.4 Required Action C.1 requires the backup nitrogen gas supply system capacity to be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the capacity is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one or more ADVs. CTS 3.7.4 Required Action E.1 requires the ADV to be declared inoperable immediately when the Required Action and associated Completion Time of Condition C is not met. This requires CTS 3.7.4 Condition A to be entered when one of the ADVs is inoperable and CTS 3.7.4 Condition B to be entered when both ADVs are inoperable. Thus, the combination of the ACTIONS allows a 6 day Completion Time when one ADV is rendered inoperable and a 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months Completion Time when two ADVs are rendered inoperable. ITS 3.7.4 contains two ACTIONS (ACTIONS A and B) written for one and two ADV lines inoperable, respectively, due to backup nitrogen gas supply system capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.7.4 ACTIONS A and B Completion Times are 6 days and 92 hours0.00106 days 0.0256 hours 1.521164e-4 weeks 3.5006e-5 months for one ADV line and two ADV lines, respectively, inoperable. This changes the CTS by summing the Completion Times of CTS 3.7.4 ACTIONS C and E into ITS ACTIONS A and B without changing the total Completion Times prior to requiring a plant shutdown. Furthermore, due to this specific change, the remaining CTS ACTIONS have been renumbered, and the two Conditions for the specific ACTIONS when one or two ADVs are inoperable (CTS 3.7.4 ACTIONS A and B) have been modified to specifically exclude the nitrogen inoperability ACTIONS.

The Conditions for ITS 3.7.4 ACTIONS C and D include a statement that they are for reasons other than Condition A (for ITS 3.7.4 Condition C) and Conditions B (for ITS 3.7.4 Condition D).

The purpose of CTS 3.7.4 ACTION C and ACTION E is to ensure enough backup nitrogen is available to reach shutdown cooling entry conditions. The proposed change to the CTS revises the ACTIONS to more closely comply with ITS convention. This change is acceptable because the ACTIONS continue to require the backup nitrogen gas supply system to be restored to the ADV(s) while not changing the overall Completion Time to perform restoration prior to a plant shutdown. This change is designated as administrative because CTS ACTIONS are being revised without any technical alterations.

A03 CTS 3.7.4 Condition B states, "Two ADVs inoperable." ITS Condition D states, "Two required ADV lines inoperable for reasons other than Condition B." This changes the CTS by adding the word "required" in Condition B. The discussion of the renumbering of the Condition and the addition of the phrase "for reasons other than Condition B" is discussed in DOC A02 and the addition of the word "lines" is discussed in DOC M01.

DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 2 of 6 The word required is used in the ISTS when the unit has more installed components than the LCO requires. In this case, the MODE 4 Applicability may only require one ADV line, if only one SG is required to be OPERABLE. Thus, the term "required" is added to ensure that ITS 3.7.4 Condition D is only entered when both ADV lines are required and both are inoperable. When one ADV line is required and inoperable, ITS 3.7.4 Condition C is entered, consistent with the same requirement in CTS 3.7.4. Specifically, CTS 3.7.4 Condition A is entered when one "required" ADV is inoperable. That is, when the LCO only required one to be OPERABLE and that one is inoperable. This change is designated as administrative because the Condition is being clarified without being technically altered. A04 CTS SR 3.7.4.1 verifies the capacity of the backup nitrogen gas supply system once per 7 days. ITS SR 3.7.4.1 requires verification that the capacity of the backup nitrogen supply system is "> 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ." This changes the CTS by adding the acceptance criterion to SR 3.7.4.1.

The purpose of SR 3.7.4.1 is to verify that there is enough backup nitrogen gas available to reach shutdown cooling conditions. The proposed change to the CTS adds acceptance criterion to SR 3.7.4.1. The addition of the > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to the SR is a clarification. The addition of the criterion to the SR is administrative since the value already exists in CTS 3.7.4 Condition C. This change is acceptable because it only clarifies that the limit is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and does not change the criterion. This change is designated as administrative because it adds clarification to the Surveillance Requirements without any technical alterations.

MORE RESTRICTIVE CHANGES

M01 CTS LCO 3.7.4 requires one ADV per required steam generator to be OPERABLE. The CTS LCO does not specifically require the ADV block valves to be OPERABLE. Furthermore, the CTS does not include any Surveillance for the ADV block valves. ITS 3.7.4 LCO requires one ADV line per required steam generator to be OPERABLE. As stated in the ITS Bases, the ADV line consists of an ADV and the associated ADV block valve. Additionally, the CTS Conditions and Required Actions only reference an ADV being inoperable and having to be restored to OPERABLE status. ITS 3.7.4 references ADV lines and requires restoration of ADV lines. The ITS also includes SR 3.7.4.3 which requires verification of one complete cycle of each ADV block valve with a Frequency of in accordance with the Surveillance Frequency Control Program. This changes the CTS by requiring ADV lines to be OPERABLE, which essentially adds the ADV block valves to Technical Specifications. This also changes the CTS by adding an SR to verify one complete cycle of each ADV block valve.

The purpose of ITS 3.7.4 is to ensure a safety grade method for cooling the unit to shutdown cooling entry conditions is available should the preferred method, via the steam bypass system to the condenser, not be available. This change to CTS 3.7.4 ensures the ADV line is OPERABLE versus just the ADV. This change essentially adds the ADV block valves to Technical Specifications. The design must accommodate the single failure of one ADV to close on demand; DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 3 of 6 therefore, the ADVs are equipped with block valves in the event an ADV spuriously opens, or fails to close during use. This change is acceptable because the ADV line is required to be OPERABLE to ensure the unit can be cooled to shutdown cooling entry conditions in the event of one of the steam generators becomes unavailable. SR 3.7.4.3 is being added to verify the function of the ADV block valve, which is to isolate a failed open ADV. Cycling the block valve closed and open demonstrates its capability to perform this function. This change is designated as more restrictive because additional requirements are being added to the ITS than are required by the CTS.

M02 CTS 3.7.4 Required Action A.1 requires an ADV to be restored to OPERABLE status and is modified by a Note which states LCO 3.0.4 is not applicable. ITS 3.7.4 Required Action C.1 requires the ADV line to be restored to OPERABLE status, but does not include the Note stating LCO 3.0.4 is not applicable. This changes the CTS by deleting the exception to LCO 3.0.4 from the Required

Action. The purpose of the Note to CTS 3.7.4 Required Action A.1 is to allow the unit to continue MODE changes during startup with one ADV inoperable. The proposed change to CTS 3.7.4 Required Action A.1 deletes the Note. Thus, if one ADV line (see DOC M01 for the change from ADV to ADV line) is inoperable, ITS 3.7.4 will only allow MODE changes using the allowances of ITS LCO 3.0.4.b, which requires performance of a risk assessment prior to changing MODES. This change adds the requirement to perform a risk assessment in order to enter the MODES of Applicability while the LCO is not met. Therefore, this change is considered acceptable. This change is designated as more restrictive because additional requirements are being added to the ITS than are required by the CTS.

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES

LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.7.4.1 requires verification of the backup nitrogen supply system capacity every 7 days. ITS SR 3.7.4.1 requires a similar Surveillance and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified frequency for the SR and the Bases for the frequency to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 4 of 6 a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program;

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

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

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

Therefore, the process will not be discussed further here.

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

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

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

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

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

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

This change proposes to relocate various Frequencies for the performance of the Surveillance Requirements to a licensee-controlled program using an NRC approved methodology for control of the Surveillance Frequencies. The Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies are not under NRC control, such as Surveillances that are performed in accordance with the Inservice Testing Program or the Containment Leakage Rate Testing Program, where the Frequencies vary based on the past DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 5 of 6 performance of the subject components. Thus, this proposed change meets criterion 1 above.

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

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

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence

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

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

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

Redundancy, diversity, and independence of safety systems are considered as part of the risk categorization to ensure that these qualities are not adversely affected. Independence of barriers and defense against common cause failures are also considered in the categorization. The improved understanding of the relative importance of plant components to risk resulting

from the development of this program promotes an improved overall understanding of how the SSCs contribute to the plant's defense-in-depth.

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 6 of 6 Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

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

NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," will require that changes in core damage frequency or risk are small and consistent with the intent of the Commission's Safety Goal Policy.

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

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

Therefore, the proposed change is consistent with the guidance in Regulatory

Guide 1.174.

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

LESS RESTRICTIVE CHANGES None Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

ADVs 3.7.4 CEOG STS 3.7.4-1 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX U2/U3 CTS 13.7 PLANT SYSTEMS

3.7.4 Atmospheric Dump Valves (ADVs)

LCO 3.7.4

[Two] ADV line s shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, [MODE 4 when steam generator is being relied upon for heat removal

].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. One required ADV line inoperable.

A.1 Restore ADV line to OPERABLE status.

7 days B. Two or more [required] ADV lines inoperable.

B.1 Restore all but one ADV line to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

[ AND C.2 Be in MODE 4 without reliance upon steam generator for heat removal.

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

[24] hours ]

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.

1 Verify one complete cycle of each ADV.

[18] months 18 INSERT 2 2 In accordance with the Inservice Testin g Pro g ramLCO 3.7.4 A pplicability A CTION A A CTION B A CTION D SR 3.7.4.2 4 2 1 2 2 2 3 5 C D E C D E INSERT 1 3 1 3 3One p er re quired steam g enerato r for reasons other than Condition A for reasons other than Condition B 3 3 72 hou r s 3.7.4 Insert Page 3.7.4-1 U2/U3 CTS INSERT 1 A. One required ADV line inoperable due to backup nitrogen gas supply system

capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

A.1 Restore ADV line to OPERABLE status.

6 days B. Two required ADV lines inoperable due to backup nitrogen gas supply system

capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

B.1 Restore one ADV line to OPERABLE status.

96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months

INSERT 2

SR 3.7.4.1 Verify the capacity of the backup nitrogen supply system is > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

In accordance

with the Surveillance

Frequency Control Program SR 3.7.4.1 3 ACTION C ACTION C 3 ADVs 3.7.4 CEOG STS 3.7.4-2 Rev. 3.0, 03/31/04 San Onofre -- Draft Amendment XXX U2/U3 CTS 1SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.4.2 [ Verify one complete cycle of each ADV block valve.

[18] months

] 3 In accordance with the Surveillance Frequency Control Program TSTF-425-A 2 3DOC M01 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. Two ACTIONS (ITS ACTION A and B) are being added to the ISTS for the backup nitrogen gas supply system when the system renders one and two ADV lines inoperable. The ACTIONS require restoration within 6 days when one required ADV line is rendered inoperable and 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months when two required ADV lines are inoperable due to an inoperable nitrogen gas supply system(s). The backup nitrogen gas supply system is required to be OPERABLE for the ADV line to be OPERABLE at SONGS. In addition an SR (SR 3.7.4.1) is being added to verify a backup nitrogen gas supply system with a capacity of > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Frequency of the SR is "In accordance with the Surveillance Frequency Control Program," consistent with TSTF-425 allowances. The addition of this new SR results in the renumbering of all subsequent SRs in the ISTS. Also, due to the addition of the new Conditions, "for reasons other than Condition A/B" is being added to the renumbered Conditions C

and D.

4. The ISTS LCO 3.7.4 is being changed from "Two ADV lines shall be OPERABLE" to "One ADV line per required steam generator shall be OPERABLE." The ISTS is written such that there are two ADV lines per SG. SONGS has just one ADV line per SG and in MODE 4 SONGS could have one SG being utilized for heat removal. If the LCO required two ADV lines to be OPERABLE, SONGS would be in an ACTION unnecessarily. Therefore, the LCO was changed to require one ADV line per required steam generator. Also, due to SONGS just having one ADV line per steam generator, the Completion Time for ACTION A was changed from 7 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . These changes are also consistent with the SONGS Units 2 and 3 CTS.

5. The Frequency for ISTS SR 3.7.4.1 (verify one complete cycle of each ADV) is being changed from a bracketed value consistent with a units refueling outage to "In accordance with the Inservice Testing Program." The SONGS IST Program includes the ADV valve cycling requirements. This change is consistent with SONGS Units 2 and 3 CTS. In addition, due to this plant specific change, TSTF-425 which allows the Frequency to be relocated to the Surveillance Frequency Control Program, has not been adopted.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

ADVs B 3.7.4 CEOG STS B 3.7.4-1 Rev. 3.0, 03/31/04 San Onofre -- Draft Revision XXX 1B 3.7 PLANT SYSTEMS

B 3.7.4 Atmospheric Dump Valves (ADVs)

BASES BACKGROUND The ADVs provide a safety grade method for cooling the unit to Shutdown Cooling (SDC) System entry conditions, should the preferred heat sink via the Steam Bypass System to the condenser not be available, as discussed in the FSAR, Section

[10.3] (Ref. 1). This is done in conjunction with the Auxiliary Feedwater System providing cooling water from the condensate storage tank (CST). The ADVs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintenance of a vacuum in the condenser to permit use of the Steam Bypass System.

Four ADV lines are provided. Each ADV line consists of one ADV and an associated block valve. Two ADV lines per steam generator are required to meet single failure assumptions following an event rendering one steam generator unavailable for Reactor Coolant System (RCS) heat removal.

The ADVs are provided with upstream block valves to permit their being tested at power, and to provide an alternate means of isolation. The ADVs are equipped with pneumatic controllers to permit control of the cooldown rate.

The ADVs are usually provided with a pressurized gas supply of bottled nitrogen that, on a loss of pressure in the normal instrument air supply, automatically supplies nitrogen to operate the ADVs. The nitrogen supply is sized to provide sufficient pressurized gas to operate the ADVs for the time required for RCS cooldown to the SDC System entry conditions.

A description of the ADVs is found in Reference 1. The ADVs are OPERABLE with only a DC power source available. In addition, hand wheels are provided for local manual operation.

APPLICABLE The design basis of the ADVs is established by the capability to cool the SAFETY unit to SDC System entry conditions. A cooldown rate of 75°F per hour ANALYSES is obtainable by one or both steam generators. This design is adequate to cool the unit to SDC System entry conditions with only one ADV and one steam generator, utilizing the cooling water supply available in the CST. U Two stored in accumulators 1 2 5 1 1 1 s ADVs B 3.7.4 CEOG STS B 3.7.4-2 Rev. 3.0, 03/31/04 San Onofre -- Draft Revision XXX 1BASES

APPLICABLE SAFETY ANALYSES (continued)

In the accident analysis presented in the FSAR, the ADVs are assumed to be used by the operator to cool down the unit to SDC System entry conditions for accidents accompanied by a loss of offsite power. Prior to the operator action, the main steam safety valves (MSSVs) are used to maintain steam generator pressure and temperature at the MSSV setpoint. This is typically 30 minutes following the initiation of an event. (This may be less for a steam generator tube rupture (SGTR) event.) The limiting events are those that render one steam generator unavailable for RCS heat removal, with a coincident loss of offsite power; this results

from a turbine trip and the single failure of one ADV on the unaffected steam generator. Typical initiating events falling into this category are a main steam line break upstream of the main steam isolation valves, a feedwater line break, and an SGTR event (although the ADVs on the affected steam generator may still be available following a SGTR event).

The design must accommodate the single failure of one ADV to open on

demand; thus, each steam generator must have at least two ADVs. The ADVs are equipped with block valves in the event an ADV spuriously opens, or fails to close during use.

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

LCO [Two] ADV line s are required to be OPERABLE on each steam generator to ensure that at least one ADV is OPERABLE to conduct a unit cooldown following an event in which one steam generator becomes unavailable , accompanied by a single active failure of one ADV line on the unaffected

steam generator. The block valves must be OPERABLE to isolate a failed open ADV. A closed block valve does not render it or its ADV line inoperable if operator action time to open the block valve is supported in the accident analysis.

Failure to meet the LCO can result in the inability to cool the unit to SDC System entry conditions following an event in which the condenser is unavailable for use with the Steam Bypass System.

An ADV is considered OPERABLE when it is capable of providing a controlled relief of the main steam flow, and is capable of fully opening and closing on demand.

U One is 1 1 1 5 1 2, and has an associated backup nitrogen gas supply system with a capacity of > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1

ADVs B 3.7.4 CEOG STS B 3.7.4-3 Rev. 3.0, 03/31/04 San Onofre -- Draft Revision XXX 1BASES

APPLICABILITY In MODES 1, 2, and 3, [and in MODE 4, when steam generator is being relied upon for heat removal,] the ADVs are required to be OPERABLE.

In MODES 5 and 6, an SGTR is not a credible event.

ACTIONS A.1 With one required ADV line inoperable, action must be taken to restore the OPERABLE status within 7 days. The 7 day Completion Time takes into account the redundant capability afforded by the remaining OPERABLE ADV lines, and a nonsafety grade backup in the Steam Bypass System and MSSVs.

B.1 With [two] or more [

required] ADV lines inoperable, action must be taken to restore

[one] of the ADV lines to OPERABLE status. As the block valve can be closed to isolate an ADV, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperable ADV lines, based on the availability of the Steam Bypass System and MSSVs, and the low probability of an event occurring during this period that requires the ADV lines.

C.1 and C.2 If the ADV lines cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4, without reliance upon the steam generator for heat removal, within

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

SURVEILLANCE SR 3.7.4.

1 REQUIREMENTS To perform a controlled cooldown of the RCS, the ADVs must be able to be opened and throttled through their full range. This SR ensures the ADVs are tested through a full control cycle at least once per fuel cycle. Performance of inservice testing or use of an ADV during a unit cooldown may satisfy this requirement. Operating experience has shown that these components usually pass the SR when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

MSLB, FWLB, or are s 18 2INSERT 2 , "In accordance with the IST Program," 2 3 1 1 3 2 2 3 1 3 C E D INSERT 1 3 3 3for reasons other than backup nitrogen gas supply system capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B 3.7.4 Insert Page B 3.7.4-3 INSERT 1 A.1 and B.1 If backup nitrogen gas supply system capacity for one or more required ADV lines is less than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , action should be taken to restore nitrogen gas supply system capacity in 6 days if one ADV line is rendered inoperable and 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months if two ADV lines are rendered inoperable. The backup nitrogen capacity is controlled to a minimum accumulator pressure of 1018 psig (1060 psig including total loop uncertainty (Ref. 2)). This pressure represents enough backup nitrogen gas system capacity for each ADV to have up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of pneumatic operation. This time period is consistent and conservative relative to the SONGS Units 2 and 3 emergency operating instructions.

The Completion Times are based on operating experience and on the fact that the normal operating instrument air supply system is still available.

INSERT 2 SR 3.7.4.1

This SR ensures there is sufficient backup nitrogen to reach shutdown cooling following a Small Break Loss of Coolant Accident (SBLOCA) or natural circulation cooldown. A minimum accumulator pressure of 1018 psig (1060 psig including total loop uncertainty (Ref. 2)) is used to ensure sufficient backup nitrogen capacity. This pressure includes allowances for seven days worth of leakage and uncertainty in the nitrogen consumption rates and subsequent 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of operation.

The Frequency is controlled under the Surveillance Frequency Control Program.

3 3 ADVs B 3.7.4 CEOG STS B 3.7.4-4 Rev. 3.0, 03/31/04 San Onofre -- Draft Revision XXX 1BASES SURVEILLANCE REQUIREMENTS (continued)

[ SR 3.7.4.

2 The function of the ADV block valve is to isolate a failed open ADV.

Cycling the block valve closed and open demonstrates its capability to perform this function. Performance of inservice testing or use of the block valve during unit cooldown may satisfy this requirement. Operating experience has shown that these components usually pass the SR when

performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

]

REFERENCES 1. FSAR, Section

[10.3]. U 2. Calculation J-ABB-031, "ADV Nitrogen Supply Pressure Indicator Uncertainty." INSERT 3 3 TSTF-425-A 2 3 2 2 1 1 1 B 3.7.4 Insert Page B 3.7.4-4 INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program.

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

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

TSTF-425-A 4 6 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4 BASES, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

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

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

ITS. 5. SONGS Units 2 and 3 each have two ADV lines, one per SG.

6. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

San Onofre Unit 2 and 3 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 5 ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

AFW System 3.7.5 ITS 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5Three AFW trains shall be OPERABLE.

NOTES----------------------------1.Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.2.The steam driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant

shut-downs, and AFW pump and valve testing.

APPLICABILITY:MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIME A.One steam supply to turbine driven AFW pump inoperable.

OR-----------NOTE-----------

Only applicable if

MODE 2 has not been

entered following

refueling

One turbine driven AFW

pump inoperable in

MODE 3 following

refueling.A.1Restore affected equipment to OPERABLE

status.7 days AND 10 days from discovery of failure to meet the LCOB.One AFW train inoperable for reasons other than Condition A

in MODE 1, 2, or 3

.B.1 Restore AFW train to

OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCOC.Two AFW trains with two motor driven pumps inoperable in MODES 1, 2, or 3.C.1 Restore one AFW train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (continued)

LCO 3.7.5 LCO 3.7.5 Notes 1 and 2 ApplicabilityACTION AACTION B------------------------------NOTE------------------------------

LCO 3.0.4.b is not applicable.

Turbine driven AFW train inoperabledue to one inoperable steam supply.

A01 A02 A03 L01 A03 L01 M01SAN ONOFRE--UNIT 23.7-11Amendment No. 223 AFW System3.7.5ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIME D.Two AFW trains withone motor driven pumpand steam driven pumpinoperable in MODES 1,2, or 3.D.1 Restore one AFW train to OPERABLE status.24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months E.Required Action andassociated Completion Time of Condition s A,B, C, or D not met.E.1 Be in MODE 3.AND E.2 Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hours F.Three AFW trainsinoperable in MODE 1, 2, or 3.F.1 --------NOTE---------LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action torestore one AFW train to OPERABLE status.Immediately(continued)ACTION CACTION DACTION E CINSERT 1the steam supply to the turbine driven CINSERT 2 D orINSERT 3 D D E EA01M01M02M01M02M01M01SAN ONOFRE--UNIT 23.7-12Amendment No. 127 Insert Page 3.7-12 INSERT 1 Turbine driven AFW train inoperable due to

an inoperable steam

supply. AND One motor driven AFW train inoperable.

INSERT 2

OR C.2 Restore the motor driven AFW train to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

INSERT 3 OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other

than Condition C.

M02 M02 M01 AFW System3.7.5ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIME G.Required AFW traininoperable in MODE 4.

G.1--------NOTE---------LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action torestore one AFW train to OPERABLE status.ORG.2Verify two Loops ofdecay heat OPERABLEin accordance withLCO 3.4.6.ImmediatelyImmediatelyH.--------NOTE---------Testing pursuant toTechnicalSpecification 3.3.5 or 3.3.6 does notconstitute entry intothis condition.----------------------An automatic valve inany flow pathincapable of closingupon receipt of a MainSteam Isolationsignal.H.1Close the affectedvalve or its blockvalve.ANDH.2Enter the appropriateACTIONS (A, B, C, D,F, or G) if there isa loss of the flowpath(s).4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sImmediatelyupon completionof ACTION H.1ACTION F NA F FA01M01A04L02SAN ONOFRE--UNIT 23.7-13Amendment No. 127 AFW System3.7.5ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.5.1Verify each AFW manual, power operated, andautomatic valve in each water flow path andin both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.31 days SR 3.7.5.2-------------------NOTE--------------------Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify the developed head of each AFW pumpat the flow test point is greater than or equal to the required developed head.In accordance with the Inservice Testing ProgramSR 3.7.5.3-------------------NOTE--------------------Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify each AFW automatic valve actuates tothe correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201.24 months(continued)SR 3.7.5.1SR 3.7.5.2SR 3.7.5.3In accordance with theSurveillance FrequencyControl ProgramIn accordance with theSurveillance FrequencyControl Program 2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.

1.that is not locked,sealed, or otherwisesecured in positionA01LA01A05LA01L03SAN ONOFRE--UNIT 23.7-14Amendment No. 147, 191 SURVEILLANCE REQUIREMENTS (continued)AFW System3.7.5ITSSURVEILLANCEFREQUENCY SR 3.7.5.4-------------------NOTE--------------------Not required to be performed for theturbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify each AFW pump starts automaticallyon an actual or simulated actuation signal.24 monthsSR 3.7.5.5Verify the proper alignment of the requiredAFW flow paths by verifying flow from the condensate storage tank to each steam generator.Prior to entering MODE 2 whenever unit has been in MODE 5 or 6 for> 30 daysSR 3.7.5.4SR 3.7.5.5In accordance with theSurveillance FrequencyControl Program

1. 2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.when in MODE 1, 2, or 3, or defueled for a cumulative period of, MODEA01LA01A05A05A06SAN ONOFRE--UNIT 23.7-15Amendment No. 127, 147 AFW System 3.7.5 ITS 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5Three AFW trains shall be OPERABLE.

NOTES----------------------------1.Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.2.The steam driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant

shut-downs, and AFW pump and valve testing.

APPLICABILITY:MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIME A.One steam supply to turbine driven AFW pump inoperable.

OR-----------NOTE-----------

Only applicable if

MODE 2 has not been

entered following

refueling

One turbine driven AFW

pump inoperable in

MODE 3 following

refueling.A.1Restore affected equipment to OPERABLE

status.7 days AND 10 days from discovery of failure to meet the LCOB.One AFW train inoperable for reasons other than Condition A

in MODE 1, 2, or 3

.B.1 Restore AFW train to

OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCOC.Two AFW trains with two motor driven pumps inoperable in MODES 1, 2, or 3.C.1 Restore one AFW train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (continued)

LCO 3.7.5 LCO 3.7.5 Notes 1 and 2 ApplicabilityACTION AACTION B------------------------------NOTE------------------------------

LCO 3.0.4.b is not applicable.

Turbine driven AFW train inoperabledue to one inoperable steam supply.

A01 A02 A03 L01 A03 L01 M01SAN ONOFRE--UNIT 33.7-11Amendment No. 216 AFW System3.7.5ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIMED.Two AFW trains withone motor driven pumpand steam driven pumpinoperable in MODES 1,2, or 3.D.1 Restore one AFW train to OPERABLE status.24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months E.Required Action andassociated CompletionTime of Condition s A,B, C, or D not met.E.1 Be in MODE 3.AND E.2 Be in MODE 4.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s12 hours F.Three AFW trainsinoperable in MODE 1,2, or 3.F.1 --------NOTE---------LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action torestore one AFW train to OPERABLE status.Immediately(continued)ACTION CACTION DACTION E CINSERT 1the steam supply to the turbine driven CINSERT 2 D orINSERT 3 D D E EA01M01M02M01M01M02M01SAN ONOFRE--UNIT 33.7-12Amendment No. 116 Insert Page 3.7-12 INSERT 1 Turbine driven AFW train inoperable due to

an inoperable steam

supply. AND One motor driven AFW train inoperable.

INSERT 2

OR C.2 Restore the motor driven AFW train to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

INSERT 3 OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other

than Condition C.

M02 M02 M01 AFW System3.7.5ITSACTIONS (continued)CONDITIONREQUIRED ACTIONCOMPLETION TIME G.Required AFW traininoperable in MODE 4.

G.1--------NOTE---------LCO 3.0.3 and all otherLCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action torestore one AFW train to OPERABLE status.ORG.2Verify two Loops ofdecay heat OPERABLE inaccordance with LCO3.4.6.ImmediatelyImmediatelyH.---------NOTE--------

-Testing pursuant toTechnicalSpecification 3.3.5or 3.3.6 does notconstitute entry intothis condition.---------------------

-An automatic valve inany flow pathincapable of closingupon receipt of aMain Steam Isolationsignal.H.1Close the affected valveor its block valve.ANDH.2Enter the appropriateACTIONS (A, B, C, D, F,or G) if there is a lossof the flow path(s).4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sImmediatelyupon completionof ACTION H.1ACTION F NA F FA01M01A04L02SAN ONOFRE--UNIT 33.7-13Amendment No. 116 AFW System3.7.5ITSSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.5.1Verify each AFW manual, power operated, andautomatic valve in each water flow path andin both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.31 days SR 3.7.5.2-------------------NOTE--------------------Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify the developed head of each AFW pumpat the flow test point is greater than or equal to the required developed head.In accordance with the Inservice Testing ProgramSR 3.7.5.3-------------------NOTE--------------------Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify each AFW automatic valve actuates tothe correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201.24 months(continued)SR 3.7.5.1SR 3.7.5.2SR 3.7.5.3In accordance with theSurveillance FrequencyControl ProgramIn accordance with theSurveillance FrequencyControl Program 2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.

1.that is not locked,sealed, or otherwisesecured in positionA01LA01A05LA01L03SAN ONOFRE--UNIT 33.7-14Amendment No. 139, 182 SURVEILLANCE REQUIREMENTS (continued)AFW System3.7.5ITSSURVEILLANCEFREQUENCY SR 3.7.5.4-------------------NOTE--------------------Not required to be performed for theturbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify each AFW pump starts automaticallyon an actual or simulated actuation signal.24 monthsSR 3.7.5.5Verify the proper alignment of the requiredAFW flow paths by verifying flow from the condensate storage tank to each steam generator.Prior to entering MODE 2 whenever unit has been in MODE 5 or 6 for> 30 daysSR 3.7.5.4SR 3.7.5.5In accordance with theSurveillance FrequencyControl Program

1. 2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.when in MODE 1, 2, or 3, or defueled for a cumulative period of, MODE A01LA01A05A05A06SAN ONOFRE--UNIT 33.7-15Amendment No. 116, 139 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 1 of 9 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

A02 ITS 3.7.5 ACTIONS include a Note that states LCO 3.0.4.b is not applicable. CTS 3.7.5 does not include this Note. This changes the CTS by including the ACTIONS Note excluding the use of LCO 3.0.4.b.

This change is consistent with TSTF-359. The purpose of the ITS 3.7.5 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.7.5 with an inoperable AFW train(s). Currently, CTS 3.7.5 and LCO 3.0.4 preclude entering MODE 4 when steam generator is relied upon for heat removal and an AFW train is inoperable. However, CTS 3.0.4 has been modified as described in the Discussion for Changes for ITS Section 3.0. ITS LCO 3.0.4 allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable. ITS LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability of a Specification if a risk assessment is performed and determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. This addition of this Note (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable AFW train(s),

and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.7.5 and LCO 3.0.4 do not currently allow this option (i.e., MODES changes are not allowed while in the ACTIONS of this Specification). This change is considered administrative because it does not result in technical changes to the CTS.

A03 CTS 3.7.5 Condition A (first Condition) states, "One steam supply to turbine driven AFW pump inoperable." CTS 3.7.5 Condition B states, "One AFW train inoperable for reasons other than Condition A in MODE 1, 2, or 3." ITS 3.7.5 Condition A (first Condition) states, "Turbine driven AFW train inoperable due to an inoperable steam supply." ITS 3.7.5 Condition B states, "One AFW train inoperable in MODE 1, 2, or 3 for reasons other than Condition A." This changes the CTS by rewording the Conditions.

The changes to CTS 3.7.5 Conditions A and B are acceptable because they do not technically change the intent of the CTS Conditions. The intent of Condition A still focuses on an inoperable steam supply and the change to Condition B is consistent with TSTF-412. These changes are designated as administrative because CTS 3.7.5 Conditions A and B are reworded without technically changing the intent.

DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 2 of 9 A04 CTS 3.7.5 ACTION G provides the requirements when the required AFW train is inoperable in MODE 4. The Required Actions require action to be initiated to restore one AFW train to OPERABLE status (CTS 3.7.5 Required Action G.1) or to verify two loops of decay heat OPERABLE in accordance with LCO 3.4.6 (CTS 3.7.5 Required Action G.2). ITS 3.7.5 ACTION G is for a similar Condition, but only requires initiation of action to restore one AFW train to OPERABLE status; the second Required Action is not included in the ITS. This changes the CTS by deleting the requirement in CTS 3.7.5 to verify two loops of decay heat OPERABLE in accordance with LCO 3.4.6 when the required AFW train is inoperable in MODE 4.

The purpose of ITS 3.7.5 ACTION G is to ensure appropriate action is taken to ensure a method of decay heat removal is available in MODE 4. The proposed change deletes the Required Action that requires verification that two loops of decay heat removal are OPERABLE in accordance with LCO 3.4.6 in MODE 4.

Specifically requiring LCO 3.4.6 to be verified in the ACTIONS of LCO 3.7.5 in MODE 4 is not necessary. LCO 3.4.6 requirements are required to be complied with in MODE 4 as required by the TS 3.4.6 Applicability. Furthermore, if the CTS 3.4.6 LCO requirements are met using two shutdown cooling subsystems, then the CTS 3.7.5 MODE 4 requirement is not applicable anymore. Therefore, since exiting the Applicability is always an option, it does not need to be specified as a Required Action. This change is acceptable because a redundant requirement, which is essentially a cross-reference, is being deleted. This change is designated as administrative because the redundant information being deleted will not technically change the intent of the TS.

A05 CTS SR 3.7.5.3 requires verification each AFW automatic valve actuates to the correct position on an actual or simulated signal, except valves HV-8200 and HV-8201. CTS SR 3.7.5.4 requires verification each AFW pump starts automatically on an actual or simulated actuation signal. The Applicability for CTS 3.7.5 is MODES 1, 2, and 3, and MODE 4 when the steam generator is relied upon for heat removal. ITS SR 3.7.5.3 and SR 3.7.5.4 require similar

Surveillances; however, the SRs are modified by a Note which states the SRs are not required to be met in MODE 4 when steam generator is relied upon for heat removal. Additionally, ITS SR 3.7.5.4 contains the wording, "when in MODES 1, 2, and 3." which makes the SR only required in MODES 1, 2, and 3.

This changes the CTS by adding a Note which modifies the SR to clarify the Applicability and adds additional wording to SR 3.7.5.4.

The purpose of the two SRs is to ensure the valves and pump actuate, as required. However, CTS 3.3.5, which provides the instrumentation requirements, does not include MODE 4. Specifically, Table 3.3.5-1 Functions 4 (Main Steam Isolation Signal), 6 (Emergency Feedwater Actuation Signal SG #1, and 7 (Emergency Feedwater Actuation Signal SG #2) are only required to be OPERABLE in MODES 1, 2, and 3. Thus, the SRs are actually not required to be met, since the signals are not required to be OPERABLE in MODE 4.

Therefore, this clarification is acceptable and considered administrative since it is matching the system SR's Applicability to the actual signal's Applicability.

A06 CTS SR 3.7.5.5 requires verifying the proper alignment of the required flow paths by verifying flow from the condensate storage tank to each steam generator prior DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 3 of 9 to entering MODE 2 whenever the unit has been in MODE 5 or 6 for > 30 days. ITS SR 3.7.5.5 requires the same surveillance, but the Frequency is being changed to prior to entering MODE 2 whenever the unit has been in MODE 5, MODE 6, "or defueled for a cumulative period of" > 30 days. This changes the CTS by adding clarifying wording to the SR.

The purpose of ITS SR 3.7.5.5 is to ensure the AFW is properly aligned prior to entering MODE 2 whenever the unit has been in an extended shutdown. The addition of clarifying wording "defueled for a cumulative period of" is acceptable because an extended shutdown also includes when the unit is defueled. The change is designated as administrative, because clarifying information is being added to the SR without technically changing the intent.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.5 ACTION C is for the Condition when two AFW trains with two motor driven pumps are inoperable in MODES 1, 2, or 3 and requires restoration of one AFW train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.7.5 ACTION D provides the requirements for the same condition, and requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restoration time when two motor driven AFW trains are inoperable and requiring the unit to shutdown. As a result of the deletion of CTS 3.7.5 ACTION C, the subsequent ACTIONS have been renumbered as part of this change.

The purpose of ITS 3.7.5 ACTION D is to limit the time two AFW trains can be concurrently inoperable other than the Condition provided in ITS 3.7.5 ACTION C. CTS 3.7.5 ACTION C allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore one motor driven AFW pump to OPERABLE status when both are inoperable. ITS 3.7.5 ACTION D requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when two motor driven AFW pumps are inoperable. The proposed change is acceptable since it appropriately limits the time the unit can continue to operate with both motor driven AFW pumps inoperable concurrently. This change is designated as more restrictive since less time is provided to restore inoperable components in the ITS than is provided in the CTS.

M02 CTS 3.7.5 ACTION D is for the Condition when two AFW trains with one motor driven pump and the steam driven pump are inoperable in MODES 1, 2, or 3. The Required Action requires the restoration of one AFW train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.7.5 ACTION C provides the requirements for a similar condition, but limits the reason for the steam driven AFW pump being inoperable to an inoperable steam supply. The Required Action requires restoration of the steam supply to the turbine driven train to OPERABLE status or restoration of the motor driven AFW train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the steam driven pump is inoperable for any other reason other than one steam supply to the pump being inoperable along with one motor driven pump inoperable, ITS 3.7.5 ACTION D requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by decreasing the Completion Time when the steam driven AFW pump is inoperable for any reason other than one steam supply to the pump being inoperable concurrent with an inoperable motor driven AFW pump, from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to requiring the unit to shutdown.

DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 4 of 9 The purpose of ITS 3.7.5 ACTION C is to limit the time one steam supply to the steam driven AFW pump is inoperable, concurrently with one motor driven AFW pump inoperable, to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.5 ACTION D allows time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to restore the steam driven AFW pump (inoperable for any reason) or the motor driven AFW pump to OPERABLE status. ITS 3.7.5 ACTION D requires the unit to be shutdown when two AFW pumps are inoperable for reasons other than Condition C (other than when one steam supply to the steam driven AFW pump and one motor driven AFW pump are inoperable). The proposed change is acceptable since it appropriately limits the time the unit can continue to operate when the steam driven AFW pump is inoperable other than when one steam supply is inoperable concurrent with one motor driven AFW pump. This change is designated as more restrictive since less time is provided to restore inoperable components in the ITS than is provided in the CTS.

RELOCATED SPECIFICATIONS None

REMOVED DETAIL CHANGES

LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.7.5.1 requires verification that each AFW manual, power operated, and automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position every 31 days. CTS SR 3.7.5.3 requires verification that each AFW automatic valve actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201 every 24 months. CTS 3.7.5.4 requires verification that each AFW pump starts automatically on an actual or simulated actuation signal once per 24 months. ITS 3.7.5 requires similar Surveillances (ISTS SRs 3.7.5.1, 3.7.5.3, and 3.7.5.4, respectively) and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program."

This changes the CTS by moving the specified frequencies for the SRs and the Bases for the frequencies to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

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

DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 5 of 9 b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1; and

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

The referenced document, NEI 04-10, Rev. 1, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC. Therefore, the process will not be discussed further here.

The relocation of the specified Surveillance Frequencies to licensee control is consistent with Regulatory Guides 1.174 and 1.177. Regulatory Guide 1.177 provides guidance for changing Surveillance Frequencies and Completion Times. However, for allowable risk changes associated with Surveillance Frequency extensions, it refers to Regulatory Guide 1.174, which provides quantitative risk acceptance guidelines for changes to core damage frequency (CDF) and large early release frequency (LERF). Regulatory Guide 1.174 provides additional guidelines that have been adapted in the risk-informed methodology for controlling changes to Surveillance Frequencies.

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

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

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

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

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

DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 6 of 9 2. The proposed change is consistent with the defense-in-depth philosophy.

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

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

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

These defense-in-depth objectives apply to all risk-informed applications, and for some of the issues involved (e.g., no over-reliance on programmatic activities and defense against human errors), it is fairly straightforward to apply them to this proposed change. The use of the multiple risk metrics of CDF and LERF and controlling the change resulting from the implementation of this initiative would maintain a balance between prevention of core damage, prevention of containment failure, and consequence mitigation. Redundancy, diversity, and independence of safety systems are considered as part of the risk categorization to ensure that these qualities are not adversely affected. Independence of barriers and defense against common cause failures are also considered in the categorization. The improved understanding of the relative importance of plant components to risk resulting

from the development of this program promotes an improved overall understanding of how the SSCs contribute to the plant's defense-in-depth.

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 7 of 9 licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

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

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

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

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

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

Therefore, the proposed change is consistent with the guidance in Regulatory

Guide 1.174.

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

LESS RESTRICTIVE CHANGES

L01 (Category 3 - Relaxation of Completion Time) CTS 3.7.5 ACTION A and ACTION B contain a second Completion time to restore the affected AFW equipment within 10 days from discovery of failure to meet the LCO. ITS 3.7.5 ACTION A and ACTION B which provide the actions for the same Conditions of CTS 3.7.5 ACTIONS A and B, do not contain this second Completion Time. This changes the CTS by deleting the second Completion Time that requires restoration of the affected inoperable AFW equipment within 10 days from discovery of failure to meet the LCO.

The second Completion Time was included in the SONGS TS and originally in the ISTS for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the ACTIONS for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

This change was initiated (in accordance with NUREG-1432 as revised by TSTF-439) due to the problems the second Completion Time presents when Completion Times are extended by risk informed methodology by complicating the presentation of the ITS and complicating the implementation of risk-informed DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 8 of 9 Completion Times. Deleting the second Completion Time is acceptable due to other regulatory requirements that are now present that were not present when the second Completion Time was proposed.

The two regulatory programs in place which provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent are the Maintenance Rule,10 CFR 50.65, and the Reactor Oversight Process, NEI 99-02.

The Maintenance Rule requires each licensee to monitor the performance of System, Structures, and Components (SSCs) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. This Rule also considers all inoperable risk-significant equipment and not just those in

the same system or those governed by the same LCO. The risk assessments performed prior to maintenance activities are governed by Regulatory Guide 1.182. Any issues associated with equipment inoperability is monitored by the NRC Resident Inspector and reported in the Corrective Action Program.

The Reactor Oversight Process: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP).

The NEI document is endorsed by RIS 2001-11, "Voluntary Submission of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs), and the Auxiliary feedwater system. Extended unavailability of these systems due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the ROP.

In addition to these regulatory programs, a requirement is being added to TS Section 1.3 which requires the licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provide an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.

This change is considered less restrictive because it results in the relaxation of the Completion Time by eliminating the requirement for the train to be restored 10 days from discovery of failure to meet the LCO.

L02 (Category 4 - Relaxation of Required Action) CTS 3.7.5 ACTION H is for the condition when an automatic valve in any flow path is incapable of closing upon receipt of a Main Steam Isolation signal. CTS 3.7.5 Required Action H.1 requires closure of the affected valve or its block valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and Required Action H.2 requires entry in the appropriate Actions (A, B, C, D, E, or G) if there is a loss of the flow path(s) immediately upon completion of ACTION H.1. ITS 3.7.5 does not contain this ACTION. This changes the CTS by deleting this specific ACTION.

DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 9 of 9 The purpose of CTS 3.7.5 ACTION H is to provide ACTIONS when automatic valves in the AFW flow path are not capable of closing upon receipt of a main

steam isolation signal (MSIS). This change essentially deletes the CTS 3.7.5 Required Action (H.1) to close the affected valve or its block valve when automatic valves in the AFW flow path is are not capable of closing upon receipt of a main steam isolation signal within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The ITS will still require the ACTION(S) for the affected flow path to be entered. ITS SR 3.7.5.3 is the Surveillance Requirement that verifies the automatic valves actuate on the associated signals. Thus, if they do not, then the associated AFW trains would be declared inoperable. This change is acceptable because the associated ACTION Completion Times are appropriate based on operating experience and the probability of an event occurring while trying to restore the affected equipment. This change is designated as less restrictive because the requirement to close affected valves that will not close on an MSIS is being deleted and the ACTIONS for the affected flow paths will be entered.

L03 (Category 5 - Deletion of a Surveillance Requirement

) CTS SR 3.7.5.3 requires verifying that each AFW automatic valve actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201. ITS SR 3.7.5.3 requires verifying that each AFW automatic valve "that is not locked, sealed, or otherwise secured in position" actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201. This changes the CTS by excluding those AFW valves that are locked, sealed or otherwise secured in position from the verification.

The purpose of CTS 3.7.5.3 is to provide assurance that if an event occurred that required the AFW valves to be in their correct position, then those requiring automatic actuation would actuate to their correct position. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. The verification of valves that are aligned and secured into the required safety position is unnecessary. Valves secured in the safety position will satisfy the safety analyses assumptions for the mitigation of analyzed accidents. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

AFW System 3.7.5 CEOG STS 3.7.5-1 Rev. 3.1, 12/01/05 U2/U3 CTS San Onofre -- Draft Amendment XXX 3.7 PLANT SYSTEMS

3.7.5 Auxiliary Feedwater (AFW) System

LCO 3.7.5

[Three] AFW trains shall be OPERABLE.

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

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, [MODE 4 when steam generator is relied upon for heat removal

].

ACTIONS

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

LCO 3.0.4.b is not applicable. -------------------------------------------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME A. [ One steam supply to turbine driven AFW

pump inoperable.

OR

NOTE------------ Only applicable if MODE 2 has not been entered following refueling. ---------------------------------

One turbine driven AFW pump inoperable in

MODE 3 following refueling.

A.1 Restore affected equipment to OPERABLE status.

7 days ] Turbine driven AFW train inoperable due to one inoperable steam supply.

TSTF-412-ALCO 3.7.5 LCO 3.7.5 Notes 1 and 2 A pplicability NA A CTION A 2 2 12. The turbine driven AFW pump is OPERABLE when running and controlled manually to support plant startups, plant shutdowns, and AFW pump and valve testing.

1. 3 2 S AFW System 3.7.5 CEOG STS 3.7.5-2 Rev. 3.1, 12/01/05 U2/U3 CTS San Onofre -- Draft Amendment XXX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train inoperable

[for reasons other than Condition A

] in MODE 1, 2, or 3.

B.1 Restore AFW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

C. Required Action and associated Completion

Time of Condition A

[or B] not met.

[ OR

[Two] AFW trains inoperable in MODE 1, 2, or 3. ]

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

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

[18] hours D. [ [Three] AFW trains inoperable in MODE 1, 2, or 3. D.1 ---------------NOTE-------------- LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status. -------------------------------------

Initiate action to restore one AFW train to OPERABLE status.

Immediately

] in MODE 1, 2, or 3 D INSERT 1 , B, or C for reasons other than Condition C D D E E TSTF-412-A TSTF-412-A 12 A CTION B A CTION E A CTION F 2 2 2 1 3.7.5 Insert Page 3.7.5-2 U2/U3 CTS INSERT 1 C. Turbine driven AFW train inoperable due to

an inoperable steam

supply.

AND One motor driven AFW train inoperable.

C.1 Restore the steam supply to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

[24 or 48] hours

[24 or 48] hours TSTF-412-A 2 2 ACTION C AFW System 3.7.5 CEOG STS 3.7.5-3 Rev. 3.1, 12/01/05 U2/U3 CTS San Onofre -- Draft Amendment XXX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required AFW train inoperable in MODE 4.

E.1 ---------------NOTE--------------

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one

AFW train is restored to OPERABLE status. -------------------------------------

Initiate action to restore one AFW train to OPERABLE status.

Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify each AFW manual, power operated, and automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

31 days SR 3.7.5.2 -------------------------------NOTE------------------------------ Not required to be performed for the turbine driven AFW pump until

[24] hours after reaching

[800] psig in the steam generators. ---------------------------------------------------------------------

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program F F In accordance with the Surveillance Frequency Control Program TSTF-412-A TSTF-425-A A CTION G 72 SR 3.7.5.1 SR 3.7.5.2 2 1 AFW System 3.7.5 CEOG STS 3.7.5-4 Rev. 3.1, 12/01/05 U2/U3 CTS San Onofre -- Draft Amendment XXX SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 ------------------------------NOTES-----------------------------

1. Not required to be performed for the turbine driven AFW pump until

[24] hours after reaching

[800] psig in the steam generators.

2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal. ---------------------------------------------------------------------

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated

actuation signal.

[18] months SR 3.7.5.4 ------------------------------NOTES----------------------------- 1. Not required to be performed for the turbine driven AFW pump until

[24] hours after reaching

[800] psig in the steam generators.

2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal. ---------------------------------------------------------------------

Verify each AFW pump starts automatically on an actual or simulated actuation signal when in MODE 1, 2, or 3.

[18] months SR 3.7.5.5 Verify the proper alignment of the required AFW flow paths by verifying flow from the condensate storage tank to each steam generator.

Prior to entering MODE 2 whenever unit has

been in MODE 5, MODE 6, or defueled for a cumulative period

of > 30 days

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program TSTF-425-A TSTF-425-A 72 72 , except valves HV-8200 and HV-8201 SR 3.7.5.4 SR 3.7.5.5 SR 3.7.5.3 2 1 1 2 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

3. ISTS LCO 3.7.5 is being changed to add a second Note which states, "The turbine driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant shut-downs, and AFW pump and valve testing." This change is consistent with SONGS Units 2 and 3 TS Amendments 164 and 155, respectively, approved by the NRC in the Safety Evaluation dated 2/23/2000.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

AFW System B 3.7.5 CEOG STS B 3.7.5-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1B 3.7 PLANT SYSTEMS

B 3.7.5 Auxiliary Feedwater (AFW) System

BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3.7.6, "Condensate Storage Tank (CST)") and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)") or atmospheric dump valves (ADVs) (LCO 3.7.4, "Atmospheric Dump Valves (ADVs)"). If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.

The AFW System consists of

[two] motor driven AFW pumps and one steam turbine driven pump configured into three trains. Each motor driven pump provides 100% of AFW flow capacity; the turbine driven pump provides 100% of the required capacity to the steam generators as assumed in the accident analysis. The pumps are equipped with independent recirculation lines to prevent pump operation against a closed system.

Each motor driven AFW pump is powered from an independent Class 1E

power supply, and feeds one steam generator, although each pump has the capability to be realigned from the control room to feed the other steam generator.

One pump at full flow is sufficient to remove decay heat and cool the unit to Shutdown Cooling (SDC) System entry conditions.

The steam turbine driven AFW pump receives steam from either main

steam header upstream of the main steam isolation valve (MSIV). Each of the steam feed lines will supply 100% of the requirements of the

turbine driven AFW pump. The turbine driven AFW pump supplies a common header capable of feeding both steam generators, with DC powered control valves actuated to the appropriate steam generator by the Emergency Feedwater Actuation System (EFAS).

The AFW System supplies feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions. inside 1 2by local operation 1

AFW System B 3.7.5 CEOG STS B 3.7.5-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

BACKGROUND (continued)

The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to SDC entry conditions, and steam is released through the ADVs.

The AFW System actuates automatica lly on low steam generator level by the EFAS as described in LCO 3.3.

2 , "Engineered Safety Feature Actuation System (ESFAS) Instrumentation." The EFAS logic is designed to feed either or both steam generators with low levels, but will isolate the AFW System from a steam generator having a significantly lower steam pressure than the other steam generator. The EFAS automatically actuates the AFW turbine driven pump and associated DC operated valves and controls when required, to ensure an adequate feedwater

supply to the steam generators. DC operated valves are provided for each AFW line to control the AFW flow to each steam generator.

The AFW System is discussed in the FSAR, Section

[10.4.9] (Ref. 1).

APPLICABLE The AFW System mitigates the consequences of any event with a loss of SAFETY normal feedwater.

ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat, by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest MSSV set pressure plus 3%.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:

a. Feedwater Line Break (FWLB) and

b. Loss of normal feedwater.

In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident.

5 U 2 5 1 AFW System B 3.7.5 CEOG STS B 3.7.5-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABLE SAFETY ANALYSES (continued)

The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valve and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the EFAS logic might not detect the affected steam generator if the backflow check valve to the affected MFW header worked properly. One motor driven AFW pump would deliver to the broken MFW header at the pump runout flow until the problem was detected, and flow was terminated by the operator. Sufficient flow would be delivered to the intact steam generator

by the redundant AFW pump.

The AFW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO requires that

[three] AFW trains be OPERABLE to ensure that the AFW System will perform the design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure boundary. Three independent AFW pumps, in two diverse trains, ensure availability of residual heat removal capability for all events accompanied by a loss of offsite power and a single failure.

This is accomplished by powering two pumps from independent emergency buses. The third AFW pump is powered by a diverse means, steam driven turbine supplied with steam from a source not isolated by the closure of the MSIVs.

The AFW System is considered to be OPERABLE when the components and flow paths required to provide AFW flow to the steam generators are OPERABLE. This requires that the two motor driven AFW pumps be OPERABLE in two diverse paths, each supplying AFW to a separate steam generator. The turbine driven AFW pump shall be OPERABLE with redundant steam supplies from each of the two main steam lines upstream of the MSIVs and capable of supplying AFW flow to either of the two steam generators. The piping, valves, instrumentation, and controls in the required flow paths shall also be OPERABLE.

The LCO is modified by a Note indicating that only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

This is because of reduced heat removal requirements, the short period of time in MODE 4 during which AFW is required, and the insufficient steam supply available in MODE 4 to power the turbine driven AFW pump. 2INSERT 1 3 7 3.7.5 Insert Page B 3.7.5-3 INSERT 1 The LCO Note 2 indicating that the turbine driven AFW pump is OPERABLE when running and controlled manually to support plant startups, plant shutdowns, and AFW pump and valve testing is necessary because if a Main Steam Line Break (MSLB) occurs, causing MSIS initiation followed by EFAS initiation, while the turbine driven AFW pump is operating, the turbine driven AFW pump turbine can trip on overspeed. However, the best estimate is that by operating the turbine driven AFW Pump in manual, the cumulative core damage frequency CDF decreases by approximately 2E-10/yr. The value of 2E-10/yr is based on the assumption that the turbine driven AFW pump is operated in the manual mode approximately 500 minutes per year. This decrease in CDF is a result of the turbine driven AFW Pump being available for all other required uses while operating in manual.

3 AFW System B 3.7.5 CEOG STS B 3.7.5-4 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE and to function in the event that the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.

In MODE 4, the AFW System may be used for heat removal via the

steam generator.

In MODES 5 and 6, the steam generators are not normally used for decay heat removal, and the AFW System is not required.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

[ A.1 If one of the two steam supplies to the turbine driven AFW pumps is inoperable, or if a turbine driven pump is inoperable while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW pump, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump.

b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling outage, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c. For both the inoperability of a steam supply line to the turbine driven pump and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps; and due to the low probability of an event requiring the use of the turbine driven AFW pump.

due to one inoperable steam supply due to one inoperable steam supply for any reasonand the turbine train is still capable of performing its specified function for most postulated events due to one inoperable steam supply TSTF-412-A TSTF-412-A TSTF-412-A 2 AFW System B 3.7.5 CEOG STS B 3.7.5-5 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

ACTIONS (continued)

Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

]

B.1 With one of the required AFW trains (pump or flow path) inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and flow paths remain to supply feedwater to the steam generators.

C.1 and C.2 When either Required Action A.1 or B.1 cannot be completed within the required Completion Time, [or if two AFW trains are inoperable in MODES 1, 2, and 3

], the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

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

In MODE 4, with

[two AFW trains inoperable in MODES 1, 2, and 3

], operation is allowed to continue because only one motor driven AFW pump is required in accordance with the Note that modifies the LCO.

Although it is not required, the unit may continue to cool down and start the SDC. for an inoperable turbine driven AFW pump in MODE 3 D for reasons other than Condition C

,, C.1, or C.2 INSERT 2 TSTF-412-A TSTF-412-A 12 2 2 2System 1 3.7.5 Insert Page B 3.7.5-5 INSERT 2 C.1 and C.2

With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [24][48] hours. Assuming no single active failures when in this condition, the accident (a FWLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two AFW pumps or due to the remaining AFW pump having to feed a faulted SG].

REVIEWER'S NOTE--------------------------------------------------

Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump.

[The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump.]

[The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is reasonable based on the fact that the remaining motor driven AFW train is capable of providing 100% of the AFW flow requirements, and the low probability of an event occurring that would challenge the AFW system.]

TSTF-412-A 2 2 4 2 2 2 AFW System B 3.7.5 CEOG STS B 3.7.5-6 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

ACTIONS (continued)

D.1 Required Action D.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.

With all [three] AFW trains inoperable in MODES 1, 2, and 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.

E.1 Required Action E.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.

With one AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status or to immediately verify, by administrative means, the OPERABILITY of a second train. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.

In MODE 4, either the reactor coolant pumps or the SDC loops can be used to provide forced circulation as discussed in LCO 3.4.6, "RCS

Loops - MODE 4."

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW water and steam supply flow paths provides assurance that the proper flow paths exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulations; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

E E F F TSTF-412-A TSTF-412-A 2 AFW System B 3.7.5 CEOG STS B 3.7.5-7 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

SURVEILLANCE REQUIREMENTS (continued)

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.5.2

Verifying that each AFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that AFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of pump performance required by the ASME Code (Ref. 2). Because it is undesirable to introduce cold AFW into the steam generators while they are operating, this testing is performed on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. Performance of inservice testing, discussed in the ASME Code (Ref. 2), at 3 month intervals satisfies this requirement.

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is an insufficient steam pressure to perform the test.

SR 3.7.5.3

This SR ensures that AFW can be delivered to the appropriate steam generator, in the event of any accident or transient that generates an EFAS signal, by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal.

This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency is acceptable, based on the design reliability and operating experience of the equipment.

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions have been established. This deferral is required because there is an insufficient steam pressure to perform the test. INSERT 3 INSERT 3 TSTF-425-A TSTF-425-A/ANSI OM (Part 6)

/ANSI OM (Part 6) 1 1or MSIS 1 3.7.5 Insert Page B 3.7.5-7 INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program.

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

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

TSTF-425-A 4 6 AFW System B 3.7.5 CEOG STS B 3.7.5-8 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES

SURVEILLANCE REQUIREMENTS (continued)

Also, this SR is modified by a Note that states the SR is not required to be met in MODE 4. In MODE 4, the required AFW train is already aligned and operating.

SR 3.7.5.4

This SR ensures that the AFW pumps will start in the event of any accident or transient that generates an EFAS signal by demonstrating that each AFW pump starts automatically on an actual or simulated

actuation signal. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency is acceptable, based on the design reliability and operating experience of

the equipment.

[ This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

Note 2 states that the SR is not required to be met in MODE 4.

[In MODE 4, the required pump is already operating and the autostart function is not required.

] [In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump.]

REVIEWER'S NOTE-----------------------------------

Some plants may not routinely use the AFW for heat removal in MODE 4. The second justification is provided for plants that use a startup feedwater pump rather than AFW for startup and shutdown.

SR 3.7.5.5 This SR ensures that the AFW System is properly aligned by verifying the flow path to each steam generator prior to entering MODE 2 operation, after 30 days in any combination of MODE 5 or 6, or defueled.

OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment, and other administrative controls to ensure that flow paths remain OPERABLE. To further ensure AFW System

alignment, the OPERABILITY of the flow paths is verified following

INSERT 3 TSTF-425-A 2 4 3.7.5 Insert Page B 3.7.5-8 INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program.

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

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

TSTF-425-A 4 6 AFW System B 3.7.5 CEOG STS B 3.7.5-9 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX 1BASES SURVEILLANCE REQUIREMENTS (continued)

extended outages to determine that no misalignment of valves has occurred. This SR ensures that the flow path from the CST to the steam generators is properly aligned by requiring a verification of minimum flow capacity of 750 gpm at 1270 psi. (This SR is not required by those units that use AFW for normal startup and shutdown.)

REFERENCES 1. FSAR, Section

[10.4.9]. 2. ASME Code for Operation and Maintenance of Nuclear Power Plants. U /ANSI OM (Part 6) is OPERABLE by raising Steam Generator level by 2% using AFW flow from the CST. 1 2 1 1 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5 BASES, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

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

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

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

ITS. 5. Changes are made to be consistent with the SONGS ITS specific Specification number.

6. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

7. ISTS 3.7.5 Bases, ASA Section, contains a discussion on the possible failure of the EFAS logic to not detect a FWLB between the MFIV and containment if the backflow check valve to the affected MFW header worked properly. It goes on to state that one motor driven AFW pump would deliver flow out of the break at runout flow and the other AFW pump would deliver to the SG whose MFW header does not have the break. This requirement is not applicable to SONGS. The SONGS backflow check valve is inside containment with AFW flow entering the line downstream of the backflow check valve. This would preclude any AFW flow being delivered out a break between the MFIV and containment assuming the backflow check valve worked properly. Thus the scenario depicted in the ISTS Bases could not occur at SONGS if the backflow check valve worked properly. Therefore, this section of the ISTS Bases is being deleted for the SONGS ITS 3.7.5 Bases.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM San Onofre Unit 2 and 3 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 6 ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

CST T-121 and T-1203.7.6 s3.7 PLANT SYSTEMS3.7.6 Condensate Storage Tank (CST T-121 and T-120

)LCO 3.7.6The CST T-121 contained volume shall be

$ 144,000 gallonsand CST T-120 contained volume shall be $ 360,000 gallons

.APPLICABILITY:MODES 1, 2, and 3,MODE 4 when steam generator is relied upon for heat removal.ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIMEA.CST T-121 or T-120contained volumes notwithin limit

.A.1Verify OPERABILITY ofbackup water supply.AND A.2Restore CST T-121 andT-120 containedvolumes to withinlimit.4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sAND Once per12 hours thereafter7 daysB.Required Action andassociated CompletionTime not met.B.1Be in MODE 3.ANDB.2Be in MODE 4 withoutreliance on steamgenerator for heat removal.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s18 hoursITSLCO 3.7.6 ,SR 3.7.6.1ApplicabilityACTION AACTION B s s TwoOPERABLE s inoperableOne or two (s)to OPERABLE statusA01A02A02A02A02A02SAN ONOFRE--UNIT 23.7-16Amendment No. 127, 162 CST T-121 and T-1203.7.6 sSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.6.1Verify CST T-121 and T-120 containedvolume s are within limit

.12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sITSSR 3.7.6.1In accordance with theSurveillance FrequencyControl Program is > 144,000 gal and CST T-120contained volume is > 360,000 gal A01A02LA01A02SAN ONOFRE--UNIT 23.7-17Amendment No. 127 CST T-121 and T-1203.7.6 s3.7 PLANT SYSTEMS3.7.6 Condensate Storage Tank (CST T-121 and T-120

)LCO 3.7.6The CST T-121 contained volume shall be

$ 144,000 gallonsand CST T-120 contained volume shall be $ 360,000 gallons

.APPLICABILITY:MODES 1, 2, and 3,MODE 4 when steam generator is relied upon for heat removal.ACTIONSCONDITIONREQUIRED ACTIONCOMPLETION TIMEA.CST T-121 or T-120contained volumes notwithin limit

.A.1Verify OPERABILITY ofbackup water supply.AND A.2Restore CST T-121 andT-120 containedvolumes to withinlimit.4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sAND Once per12 hours thereafter7 daysB.Required Action andassociated CompletionTime not met.B.1Be in MODE 3.ANDB.2Be in MODE 4 withoutreliance on steamgenerator for heat removal.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s18 hoursITSLCO 3.7.6 ,SR 3.7.6.1ApplicabilityACTION AACTION B s s TwoOPERABLE s inoperableOne or two (s)to OPERABLE statusA01A02A02A02A02A02SAN ONOFRE--UNIT 33.7-16Amendment No. 116, 153 CST T-121 and T-1203.7.6 sSURVEILLANCE REQUIREMENTSSURVEILLANCEFREQUENCYSR 3.7.6.1Verify CST T-121 and T-120 containedvolume s are within limit

.12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sITSSR 3.7.6.1In accordance with theSurveillance FrequencyControl Program is > 144,000 gal and CST T-120contained volume is > 360,000 gal A01A02LA01A02SAN ONOFRE--UNIT 33.7-17Amendment No. 116 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs) San Onofre Unit 2 and 3 Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

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

A02 CTS 3.7.6 title, header, and LCO statement contain the specific CST designators (T-120 and T-121). CTS LCO 3.7.6 includes the actual limits (in gallons) for the two CSTs. CTS 3.7.6 Condition A includes the two designators and specifies that either is "not within limit." CTS 3.7.6 Required Action A.2 requires restoration of the two CSTs to "within limit," and also includes the designators.

ITS 3.7.6 title, header, LCO, and ACTIONS do not list the specific CST designators and ACTION A uses the term "inoperable" and "OPERABLE status" in lieu of "within limits." Furthermore, ITS SR 3.7.6.1 includes the CST volume limits in lieu of LCO 3.7.6. This changes the CTS by deleting the specific CST designators from the title, header, LCO, and ACTIONS, rewords portions of ACTION A (Condition and Required Action A.2) and moves the limits from the LCO to the SR.

The purpose of CTS 3.7.6 is to ensure the CSTs contain sufficient cooling water to remove decay heat consistent with the accident analysis. This change deletes the specific CST designators, rewords CTS Condition A and Required Action A.2, and removes the limits from the LCO. These changes are acceptable because the CTS is not being technically altered. The CST designators are still defined in ITS SR 3.7.6.1 and the limits are also maintained in the ITS SR 3.7.6.1. Thus, the two CSTs are still required to meet the limits. Furthermore, the terms being changed are consistent with the terminology used in the ISTS. This change is designated as administrative because the changes do not technically affect the intent of the TS.

MORE RESTRICTIVE CHANGES

None RELOCATED SPECIFICATIONS

None

DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs) San Onofre Unit 2 and 3 Page 2 of 4 REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.7.6.1 requires verification that CST T-121 and T-120 contained volumes within limit every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.6.1 requires a similar Surveillance and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified frequencies for the SRs and the Bases for the frequencies to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

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

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

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

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

Therefore, the process will not be discussed further here.

The relocation of the specified Surveillance Frequencies to licensee control is consistent with Regulatory Guides 1.174 and 1.177. Regulatory Guide 1.177 provides guidance for changing Surveillance Frequencies and Completion Times. However, for allowable risk changes associated with Surveillance Frequency extensions, it refers to Regulatory Guide 1.174, which provides quantitative risk acceptance guidelines for changes to core damage frequency (CDF) and large early release frequency (LERF). Regulatory Guide 1.174 provides additional guidelines that have been adapted in the risk-informed methodology for controlling changes to Surveillance Frequencies.

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

DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs) San Onofre Unit 2 and 3 Page 3 of 4 1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.