ML11251A086

License Amendment Requests (LAR) 260 & 246 Technical Specifications Conversion to NUREG-1432, Rev. 3.0 Plus Selected Approved Travelers

ML11251A086
Person / Time
Site:	San Onofre
Issue date:	07/29/2011
From:	Bauder D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NUREG-1432, Rev. 3.0
Download: ML11251A086 (23)

Text

SOUTHERN CALIFORNIA Douglas R. Bauder E

EO I OSite Vice President & Station Manager San Onofre Nuclear Generating Station An EDISON INTERNA TIONALk Company July 29, 2011 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 San Onofre Nuclear Generating Station, Units 2 and 3 Docket Nos. 50-361 and 50-362

Subject:

License Amendment Requests (LAR) 260 and 246 Technical Specifications Conversion to NUREG-1432, Rev. 3.0 Plus Selected Approved Travelers

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Southern California Edison (SCE) hereby submits license amendment applications 260 and 246 to operating licenses NPF-10 and NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively.

Amendment Applications 260 and 246 consist of the enclosed Proposed Change Number (PCN) 599.

SONGS was originally licensed with technical specifications (TS) as outlined in NUREG-0741 for Unit 2 and NUREG-0952 for Unit 3. In the early 1990s, SONGS became the lead Combustion Engineering type plant to convert to the Improved Technical Specifications (ITS) NUREG-1432 "Standard Technical Specifications, Combustion Engineering Plants." Because SONGS was a lead plant, SCE drafted the conversion submittal in parallel with the Industry's and the NRC's development of NUREG-1432 Rev. 0. In 1996, the NRC issued Amendments 127 (Unit 2) and 116 (Unit

3) approving the original conversion to ITS.

There were changes during the development of NUREG-1432 Rev. 0 and because the Industry and the NRC continued to improve NUREG-1432 to the point that the NRC is about to issue NUREG-1432 Rev. 4, SCE is requesting a second conversion that will convert the current SONGS TS to the ITS as outlined in NUREG-1432 Rev. 3.0, and additional approved Technical Specification Task Force (TSTF) travelers, slated for incorporation into NUREG-1432 Rev. 4, included in this submittal.

The guidance of Nuclear Energy Institute (NEI) 96-06, "Improved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC) Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," dated October 9, 1996, were used in preparing this submittal. The detailed descriptions and justifications to support the proposed changes, as well as the no significant hazards considerations, are provided as Attachment 1, "SONGS ITS Submittal, Volumes 1 through 15" to this letter.

P.O. Box 128 San Clemente. CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com

Document Control Desk -2 July 29, 2011 Included in Attachment 1 are Bases for the proposed ITS. These Bases are a summary statement of the bases or reasons for the specifications. However, the Bases are not a part of the technical specifications but are maintained consistent with the SONGS Updated Final Safety Analysis Report (UFSAR). , "Commitment List" contains the commitments made in this submittal.

The commitments contained in this submittal are only those contained in Attachment 2.

The following enclosures are also included to assist the NRC in the review of this submittal:

" Enclosure 1, "SONGS ITS Conversion Submittal Contents," describes the organization and content of the submittal, including each of the volumes in Attachment 1.

• Enclosure 2, "Beyond Scope Changes," provides a list and description of the changes included in the ITS submittal that are beyond the scope of the Improved Standard Technical Specifications (ISTS) as described in NUREG-1432, Rev.

3.0, and also beyond the scope of the CTS.

• Enclosure 3, "Disposition of Generic Changes to NUREG-1432, Rev.3.0," lists the NRC approved changes to NUREG-1432, Rev. 3.0, as of March 1, 2011, and summarizes the disposition of each of these changes in the SONGS Units 2 and 3 license amendment request.

SCE requests approval of the proposed amendment by August 1, 2012. Once approved, the amendment shall be implemented within 180 days, except for changes associated with adoption of TSTF-490, "Deletion of E Bar Definition and Revision to RCS Specific Activity Technical Specification." For TSTF-490, SCE requests implementation no later than the end of the Unit 2 Cycle 18 refueling outage to allow for associated plant modifications.

Based on the information provided in Attachment 1 to this letter, SCE has determined that there is no significant hazards consideration associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

SONGS has previously identified to the NRC that the Applicability statements "during the movement of irradiated fuel" are non-conservative based on current accident analysis calculations and is operating under Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety." While this conversion to NUREG-1432 Rev. 3.0 retains the wording "during the movement of irradiated fuel," SONGS is operating under Administrative Letter 98-10 and will be making a separate license amendment request to resolve this specific issue.

Document Control Desk July 29, 2011 In accordance with 10 CFR 50.91, SCE is notifying the State of California of this LAR by transmitting a copy of this letter and attachment/enclosures to the designated State Official.

If you have any questions or require additional information, please contact Ms. Linda T.

Conklin at (949) 368-9443.

I declare under penalty of perjury that the forgoing is true and correct.

Executed on: 7/,-ý5ý0 11 (Date)

Document Control Desk July 29, 2011 Attachments:

1. SONGS ITS Submittal, Volumes 1 through 15

2. Commitment List

Enclosures:

1. Contents of the SONGS Improved Technical Specifications (ITS) Conversion Submittal

2. Beyond Scope Changes

3. Disposition of Generic Changes to NUREG 1432, Rev. 3.0 Enclosed with this letter is a compact disk (CD), which contains this submittal's Attachments and Enclosures.

cc:

E.E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G.G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S.Y. Hsu, California Department of Public Health, Radiologic Health Branch

Document Control Desk -5 July 29, 2011 The enclosed CD contains the following files:

File Name File Size Sensitivity 001 Attachment 1.pdf 13 kbytes publicly available 002 Att 1 Vol 01 (Chapter 1.0).pdf 1,117 kbytes publicly available 003 Att 1 Vol 02 (Chapter 2.0).pdf 708 kbytes publicly available 004 Att 1 Vol 03 (Section 3.0).pdf 886 kbytes publicly available 005 Att 1 Vol 04 (Section 3.1).pdf 2,451 kbytes publicly available 006 Att 1 Vol 05 (Section 3.2).pdf 1,504 kbytes publicly available 007 Att 1 Vol 06 (Section 3.3).pdf 3,789 kbytes publicly available 008 Att 1 Vol 07 (Section 3.4).pdf 2,841 kbytes publicly available 009 Aft 1 Vol 08 (Section 3.5).pdf 1,183 kbytes publicly available 010 Aft 1 Vol 09 (Section 3.6).pdf 1,910 kbytes publicly available 011 Aft 1 Vol 10 (Section 3.7).pdf 4,034 kbytes publicly available 012 Aft 1 Vol 11 (Section 3.8).pdf 2,644 kbytes publicly available 013 Aft 1 Vol 12 (Section 3.9).pdf 1,507 kbytes publicly available 014 Aft 1 Vol 13 (Chapter 4.0).pdf 1,398 kbytes publicly available 015 Aft 1 Vol 14 (Chapter 5.0).pdf 2,122 kbytes publicly available 016 Att 1 Vol 15 (Generic NSHCs).pdf 590 kbytes publicly available 017 Attachment 2.pdf 52 kbytes publicly available 018 Enclosures 1, 2, and 3.pdf 196 kbytes publicly available

Docket Nos. 50-361 and 50-362 Attachment 1 ATTACHMENT 1 SONGS ITS SUBMITTAL AMENDMENT APPLICATIONS 260 AND 246 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1432, REV. 3.0 PLUS SELECTED APPROVED TRAVELERS SONGS UNITS 2 AND 3 ITS CONVERSION SUBMITTAL, VOLUMES 1 THROUGH 15 CONTENTS Volume 1 - ITS Chapter 1.0, Use and Application Volume 2 - ITS Chapter 2.0, Safety Limits (SLs)

Volume 3 - ITS Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability Volume 4 - ITS Section 3.1, Reactivity Control Systems Volume 5 - ITS Section 3.2, Power Distribution Limits Volume 6 - ITS Section 3.3, Instrumentation Volume 7 - ITS Section 3.4, Reactor Coolant System (RCS)

Volume 8 - ITS Section 3.5, Emergency Core Cooling Systems (ECCS)

Volume 9 - ITS Section 3.6, Containment Systems Volume 10 ITS Section 3.7, Plant Systems Volume 11 ITS Section 3.8, Electrical Power Systems Volume 12 ITS Section 3.9, Refueling Operations Volume 13 ITS Chapter 4.0, Design Features Volume 14 ITS Chapter 5.0, Administrative Controls Volume 15 Generic Determination of No Significant Hazards Considerations and Environmental Assessment Page 1 of 1

Docket Nos. 50-361 and 50-362 Attachment 2 ATTACHMENT 2 COMMITMENT LIST AMENDMENT APPLICATIONS 260 AND 246 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1432, REV. 3.0 PLUS SELECTED APPROVED TRAVELERS The following list identifies those actions committed to by Southern California Edison (SCE) for the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 in this document. Any other actions discussed in the submittal represent intended or planned actions; they are described only for information and are not regulatory commitments.

Please contact Ms. Linda T. Conklin at (949) 368-9443 for any questions regarding this document or any associated regulatory commitments.

No. Commitment Due Date/Event SCE will establish the Technical Specification 1 Bases for LCO 3.0.4, as modified, with the Upon Implementation applicable license amendment.

SCE will ensure that if LCO 3.0.4.b is used, the risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk 2 Before Maintenance Activities at Nuclear Power Upon Implementation Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

SCE will establish the Technical Specification 3 Bases for LCO 3.0.8, as adopted, with the Upon Implementation applicable license amendment.

SCE will ensure that when LCO 3.0.8a is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 42 Restriction: Upon Implementation At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s),

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Docket Nos. 50-361 and 50-362 Attachment 2 No. Commitment Due Date/Event must be available SCE will ensure that when LCO 3.0.8b is used, appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

At least one AFW train (including a 5 minimum set of supporting equipment Upon Implementation required for its successful operation) not associated with the inoperable snubber(s),

or some alternative means of core cooling (e.g., F&B, firewater system or "aggressive secondary cooldown" using the steam generators) must be available.

SCE will ensure that when LCO 3.0.8 is used appropriate plant procedures and administrative controls are revised to implement the following Tier 2 Restriction:

Every time the provisions of LCO 3.0.8 are used SCE will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable 6 of performing their required safety or Upon Implementation support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs.

non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis.

SCE will revise the UFSAR or TS Bases to In Accordance with describe the restrictions in commitments 4 and 5. IOCFR50.71(e)

SCE will ensure that when using end state 8 changes being adopted as part of TSTF-422 Upon Implementation incorporation, appropriate plant procedures and administrative controls are revised to perform a Page 2 of 4

Docket Nos. 50-361 and 50-362 Attachment 2 No. Commitment Due Date/Event risk assessment in accordance with 10 CFR 50.65(a)(4), regardless of whether maintenance is being performed. The risk assessment will follow Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," which endorses NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Section 11 guidance for implementation of 10 CFR 50.65(a)(4). SCE will also follow the industry-developed implementation guidance, WCAP-16364-NP, Rev. 0, "Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)," November 2004.

For all Frequencies being moved to the Surveillance Frequency Control Program, SCE will ensure both the current Frequencies and the basis for the Frequencies are included in the Program. Upon Implementation SCE will also ensure that any changes to the Frequencies will be in accordance with NEI 04-01, "Risk-Informed Method for Control of Surveillance Frequencies," Rev. 1.

SCE will ensure that appropriate administrative procedures are in place when using the LCO 3.9.3 Note that allows penetration flow path(s) providing direct access from the containment atmosphere to 10 the outside atmosphere to be unisolated under Upon Implementation administrative controls. The administrative procedures will ensure that in the event of a refueling accident, the open penetration(s) can and will be promptly closed.

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Docket Nos. 50-361 and 50-362 Attachment 2 SCE will ensure procedures are in place to require the continuing performance of the Hazardous Cargo Traffic Report in accordance with Regulatory Guide 1.78, "Evaluating the Habitability of Nuclear Power Plant Control Room During a 11 Upon Implementation Postulated Hazardous Chemical Release." The report will include hazardous cargo traffic on Interstate 5 and the Atchison, Topeka, and Santa Fe Railway and be submitted to the NRC regional administrator every three years.

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Docket Nos. 50-361 and 50-362 Enclosure 1 ENCLOSURE 1 SONGS ITS CONVERSION SUBMITTAL CONTENTS AMENDMENT APPLICATIONS 260 AND 246 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1432, REV. 3.0 PLUS SELECTED APPROVED TRAVELERS of the submittal for the conversion of the current Technical Specifications (CTS) to the ITS for SONGS consists of the following fifteen volumes:

Volume Title

1. ITS Chapter 1.0, Use and Application

2. ITS Chapter 2.0, Safety Limits (SLs)

3. ITS Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability

4. ITS Section 3.1, Reactivity Control Systems

5. ITS Section 3.2, Power Distribution Limits

6. ITS Section 3.3, Instrumentation

7. ITS Section 3.4, Reactor Coolant System (RCS)

8. ITS Section 3.5, Emergency Core Cooling Systems (ECCS)

9. ITS Section 3.6, Containment Systems

10. ITS Section 3.7, Plant Systems

11. ITS Section 3.8, Electrical Power Systems

12. ITS Section 3.9, Refueling Operations

13. ITS Chapter 4.0, Design Features

14. ITS Chapter 5.0, Administrative Controls

15. Generic Determination of No Significant Hazards Considerations and Environmental Assessment Page 1 of 6

Docket Nos. 50-361 and 50-362 Enclosure 1 Volumes 1 through 14 Volumes 1 through 14 provide the details and justification to support the proposed changes. Each volume corresponds to a Chapter, Section, or Specification of NUREG-1432, Rev. 3.0. Each volume contains the required information to review the conversion to ITS, and include the following:

" Individual ITS Specifications in:

o ITS Chapter (Volumes 1, 2, and 13);

o Section (Volume 3); or o Specification (Volumes 4 through 12 and 14) order.

" Relocated/Deleted CTS Specifications (if applicable); and

" ISTS Specifications not adopted in the SONGS ITS (if applicable). Note that SONGS Units 2 and 3 are digital plants, thus the Analog Specifications are not adopted and will not be included in the submittal. In addition, SONGS Units 2 and 3 are designed with an Atmospheric type of containment, so the non-Atmospheric Specifications in Section 3.6 are also not included in the submittal.

The information for each of the above three types of specifications is organized as follows:

CTS Markup and Discussion of Changes (DOCs) (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)

This section contains a markup of the CTS pages, either for CTS pages associated with an Individual ITS Specification or for Relocated/Deleted CTS Specifications, and the DOCs from the CTS.

The CTS markup pages for each ITS Specification are normally in numerical order.

However, more than one CTS Specification is sometimes used in the generation of an ITS Specification. In this case, the CTS pages that are the major contributor to the ITS Specification are shown first, followed by the remaining associated CTS pages in numerical order.

The left-hand margin of the CTS markup pages includes a cross-reference to the equivalent ITS requirement. The upper right-hand comer of the CTS markup pages is annotated with the ITS Specification number to which it applies. Items on the CTS markup pages that are addressed in other proposed ITS Chapters, Sections, or Specifications are annotated with a reference to the appropriate ITS Chapter, Section, or Specification.

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Docket Nos. 50-361 and 50-362 Enclosure 1 The CTS markup pages are annotated with an alphanumeric designator to identify the differences between the CTS and the proposed ITS. The designator corresponds to a DOC, which provides the description and justification of the change. The DOCs are located directly following the associated CTS markup for each Chapter or Section (Volumes 1, 2, 3, and 13) or each Specification (Volumes 4 through 12 and 14).

Each proposed change to the CTS is classified into one of the following categories:

Designator Category A ADMINISTRATIVE CHANGES - Changes to the CTS that do not result in new requirements or change operational restrictions or flexibility.

These changes are supported in aggregate by a single generic No Significant Hazards Consideration (NSHC).

M MORE RESTRICTIVE CHANGES - Changes to the CTS that result in added restrictions or reduced flexibility. These changes are supported in aggregate by a single generic NSHC.

R RELOCATED SPECIFICATIONS - Changes to the CTS that relocate specifications that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii). These changes are supported in aggregate by a single generic NSHC.

LA REMOVED DETAIL CHANGES - Changes to the CTS that eliminate detail and relocate the detail to a licensee-controlled document.

Typically, this involves details of system design and function, or procedural detail on methods of conducting a Surveillance Requirement. These changes are supported in aggregate by a single generic NSHC. In addition, the generic type of removed detail change is identified in italics at the beginning of the DOC.

L LESS RESTRICTIVE CHANGES - Changes to the CTS that result in reduced restrictions or added flexibility. These changes are supported either in aggregate by a generic NSHC that addresses a particular category of less restrictive change, or by a specific NSHC if the change does not fall into one of the eight categories of less restrictive changes.

If the less restrictive change is covered by a generic NSHC, the category of the change is identified in italics at the beginning of the DOC.

The DOCs are numbered sequentially within each letter designator for each ITS Chapter, Section, or Specification.

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Docket Nos. 50-361 and 50-362 Enclosure 1 The CTS Bases pages are replaced in their entirety by the proposed SONGS ITS Conversion Bases, and CTS markup pages are not provided in the ITS submittal.

ISTS Markup and Justification for Deviations (JFDs) (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the SONGS ITS Conversion)

This section contains a markup of the NUREG-1432, Rev. 3.0, ISTS pages, either for ISTS pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the SONGS ITS, and JFDs from the ISTS. The ISTS pages are annotated with a numeric designator to identify the differences between the ISTS and the proposed ITS. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS markup for each Chapter or Section (Volumes 1, 2, 3, and 13) or each Specification (Volumes 4 through 12 and 14). The ISTS markup pages are also annotated to show the incorporation of NRC-approved generic changes (Technical Specification Task Force (TSTF) change travelers) that are applicable to the SONGS ITS.

The left-hand margin of the ISTS markup pages includes a cross-reference to the equivalent CTS requirement.

ISTS Bases Markup and JFDs (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the SONGS ITS)

This section contains a markup of the NUREG-1432, Rev. 3.0, ISTS Bases pages, either for ISTS Bases pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the SONGS ITS, and JFDs from the ISTS Bases. The ISTS Bases pages are annotated with a numeric designator to identify the differences between the ISTS Bases and the proposed ITS Bases. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS Bases markup for each Chapter or Section (Volumes 1, 2, 3, and 13) or each Specification (Volumes 4 through 12 and 14). The ISTS Bases markup pages are also annotated to show the incorporation of NRC-approved generic changes (TSTF change travelers) that are applicable to the SONGS ITS Bases. The volumes for ITS Chapters 1.0, 4.0, and 5.0 do not include this section, because NUREG-1432, Rev. 3.0, does not include any Bases for these Chapters.

Determination of NSHC (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)

This section contains the determination in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c) to support a finding of NSHC. For those Page 4 of 6

Docket Nos. 50-361 and 50-362 Enclosure 1 changes covered by a generic NSHC, those generic NSHCs are located in Volume

15. For those less restrictive changes that do not fall into one of the generic less restrictive categories, a specific NSHC evaluation has been performed. Each evaluation is annotated to correspond to the DOC discussed in the NSHC. For those ITS Chapters, Sections, or Specifications for which the less restrictive DOCs all fall into a generic category, a statement that there are no specific NSHCs is provided.

Volume 15 Volume 15 contains the majority of the evaluations required by 10 CFR 50.91(a), which support a finding of No Significant Hazards Consideration (NSHC). Based on the inherent similarities in the NSHC evaluations, generic evaluations for a finding of NSHC have been written for the following categories of CTS changes:

" Administrative Changes

• More Restrictive Changes

" Relocated Specifications

• Removed Detail Changes

" Less Restrictive Changes - Category 1 - Relaxation of LCO Requirements

" Less Restrictive Changes - Category 2 - Relaxation of Applicability

• Less Restrictive Changes - Category 3 - Relaxation of Completion Time

" Less Restrictive Changes - Category 4 - Relaxation of Required Action

" Less Restrictive Changes - Category 5 - Deletion of Surveillance Requirement

" Less Restrictive Changes - Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria

• Less Restrictive Changes - Category 7 - Relaxation of Surveillance Frequency

" Less Restrictive Changes - Category 8 - Deletion of Reporting Requirements For those less restrictive changes that do not fall into one of the generic Less Restrictive Changes categories, specific NSHC evaluations have been performed and are provided in the applicable Chapter, Section, or Specification in Volumes 1 through 14.

In addition, Volume 15 contains an evaluation of environmental consideration in accordance with 10 CFR 51.21. It has been determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Page 5 of 6

Docket Nos. 50-361 and 50-362 Enclosure 1 51.22(b), and no environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment.

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Docket Nos. 50-361 and 50-362 Enclosure 2 ENCLOSURE 2 BEYOND SCOPE CHANGES AMENDMENT APPLICATIONS 260 AND 246 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1432, REV. 3.0 PLUS SELECTED APPROVED TRAVELERS Beyond Scope Changes are those changes included in the Improved Technical Specifications (ITS) conversion submittal that are beyond the scope of the Improved Standard Technical Specifications (ISTS) as described in NUREG-1432, Rev. 3.0, and also beyond the scope of the SONGS Units 2 and 3 current Technical Specifications (CTS). The following is a list of the discussions of changes (DOCs) in Attachment 1 that are Beyond Scope Changes in the SONGS ITS conversion submittal:

1) CTS 3.1.5 includes two SRs related to CEA position indication, CTS SR 3.1.5.2 and SR 3.1.5.4. However, the LCO statement of CTS 3.1.5 does not specifically delineate position indication as being required for a CEA. It only requires OPERABILITY of a full length CEA and for all part and full length CEAs to be within the alignment limits. Furthermore, the LCO Section of the CTS 3.1.5 Bases does not describe indication as a necessary feature for the CEA to be OPERABLE. However, the CTS Bases for SR 3.1.5.2 provides a requirement that two of the three indicators for each CEA to be OPERABLE. In addition, CTS 3.1.5 does not provide any specific actions to take if one or more of the required CEA position indicators is inoperable.

Consistent with the approach taken in the other PWR NUREGs (NUREGs-1430 and -1431), a new LCO has been provided for the CEA Position Indicators. (Refer to Attachment 1, Volume 4, ITS 3.1.15, DOCs A02 and L01)

2) The setpoint in SR 3.3.9.2 was changed from 4E2 cpm to 1.80E-5 pCi/cc. The two values are equivalent so no technical change has resulted. This change is the result of SCE replacing the analog radiation monitor with a digital radiation monitor as approved by License Amendments 154 and 145 for Units 2 and 3 respectively. (Refer to Attachment 1, Volume 6, ITS 3.3.9, DOC A02).

3) The 1260 amp hour batteries have been removed from SONGS and all batteries are now the 1800 amp hour batteries. Therefore, the 1200 amp hour battery requirements are being deleted from the Technical Specifications. (Refer to Attachment 1, Volume 11, ITS 3.8.4, DOCs A02 and A05 and ITS 3.8.6, DOC A02)

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Docket Nos. 50-361 and 50-362 Enclosure 2 Although not considered "Beyond Scope Changes" SCE has identified several changes which may require additional NRC Staff review. The following is a listing of those changes:

1) SCE is incorporating TSTF-422, Change in Technical Specifications End States (CE NPSD-1 186). This affects multiple ITS Specifications.

2) SCE is incorporating TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b. This affects multiple ITS Specifications.

3) SCE is incorporating TSTF-490, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. (Refer to Attachment 1, Volume 7, ITS 3.4.16 DOC L01)

4) SCE is incorporating TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions. This affects multiple Instrumentation Section Specifications.

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Docket No. 50-361 and 50-362 Enclosure 3 ENCLOSURE 3 DISPOSITION OF GENERIC CHANGES TO NUREG-1432. REV. 3.0 AMENDMENT APPLICATIONS 260 AND 246 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1432, REV. 3.0 PLUS SELECTED APPROVED TRAVELERS The following Nuclear Regulatory Commission (NRC)-approved (as of March 1, 2011) Technical Specification Task Force (TSTF) changes are adopted in whole or in part in the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Improved Technical Specifications (ITS) conversion submittal:

TSTFs Adopted TSTF Description of TSTF ITS SectionlSpecification TSTF-372-A, Addition of LCO 3.0.8, Inoperability of Snubbers 3.0.8 Rev. 4 TSTF-400-A, Clarify SR on Bypass of DG Automatic Trips 3.8.1 / (SR 3.8.1.13)

Rev. 1 TSTF-412-A, Provide Actions for One Steam Supply to Turbine 3.7.5 Rev. 3 Driven AFW/EFW Pump Inoperable TSTF-422-A, Change in Technical Specifications End States (CE Multiple Rev. 2 NPSD-1186)

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Docket No. 50-361 and 50-362 Enclosure 3 TSTFs Adopted TSTF Description of TSTF ITS Section/Specification TSTF-425-A, Relocate Surveillance Frequencies to Licensee Multiple Rev. 3 Control - RITSTF Initiative 5b TSTF-439-A, Eliminate Second Completion Times Limiting Time 1.3, 3.6.6, 3.7.5, 3.8.1, and 3.8.9 Rev. 2 From Discovery of Failure To Meet an LCO TSTF-470, Correct Title and References in PAM Instrumentation 3.3.11 / (Table 3.3.11-1, Function #8 and Rev. 0 Bases Bases)

TSTF-471-A, Eliminate use of term CORE ALTERATIONS in 1.1, 3.8.2, 3.8.5, 3.8.8, 3.8.10, 3.9.1, and 3.9.2 Rev. 1 ACTIONS and Notes TSTF-475-A, Control Rod Notch Testing Frequency and SRM Insert 1.4 Rev. 1 Control Rod Action TSTF-479-A, Changes to Reflect Revision of 10 CFR 50.55a Specification 5.5.2.10 Rev. 0 Bases 3.4.10, 3.4.14, 3.5.2, 3.6.6, 3.7.1, 3.7.2, 3.7.3, 3.7.5, and 3.8.1 TSTF-482-A, Correct LCO 3.0.6 Bases 3.0.6 (Bases only)

Rev. 0 TSTF-485-A, Correct Example 1.4-1 1.4 Rev. 0 Page 2 of 5

Docket No. 50-361 and 50-362 Enclosure 3 TSTFs Adopted TSTF Description of TSTF ITS Section/Specification TSTF-486-A, Revise MTC Surveillance for Startup Test Activity 3.1.4 Rev. 2 Reduction (STAR) Program (WCAP-16011)

TSTF-490-A, Deletion of E Bar Definition and Revision to RCS 1.1 and 3.4.16 Rev. 0 Specific Activity Tech Spec TSTF-491-A, Removal of Main Steam and Main Feedwater Valve 3.7.2 and 3.7.3 Rev. 2 Isolation Times from Technical Specifications TSTF-493-A, Clarify Application of Setpoint Methodology for LSSS 3.3.1, 3.3.5, 3.3.7, 3.3.8, and 3.3.9 Rev. 4 Functions TSTF-494, Correct Bases Discussion of Figure B3.0-1 (Note that 3.0 (Bases only)

Rev. 1 since this is a "T" traveler, a plant specific justification was provided.

TSTF-497-A, Limit Inservice Testing Program SR 3.0.2 Application 5.5.2.10 Rev. 0 to Frequencies of 2 Years or Less TSTF-501 -A, Relocate Stored Fuel Oil and Lube Oil Volume Values 3.8.3 Rev. 1 to Licensee Control TSTF-513-A, Revise PWR Operability Requirements and Actions 3.4.15 Rev. 3 for RCS Leakage Instrumentation Page 3 of 5

Docket No. 50-361 and 50-362 Enclosure 3 The following Nuclear Regulatory Commission (NRC)-approved (as of March 1, 2011) Technical Specification Task Force (TSTF) changes have previously been adopted into the SONGS Units 2 and 3 Technical Specifications.

TSTF Description of TSTF Amendment Numbers (U2/U3)

TSTF-369-A, Removal of Monthly Operating Report and 195/186 Rev. 1 Occupational Radiation Exposure Report TSTF-448-A, Control Room Habitability 250/235 Rev. 3 TSTF-449-A, Steam Generator Tube Integrity 240/224 Rev. 4 TSTF-487-A, Relocate DNB Parameters to the COLR 251/237 Rev. 1 TSTF-51 1-A, Eliminate Working Hour Restrictions from TS 5.2.2 255/241 Rev. 0 to Support Compliance with 10 CFR Part 26 Page 4 of 5

Docket No. 50-361 and 50-362 Enclosure 3 The following NRC-approved (as of March 1, 2011) TSTF changes have not been included in the SONGS Units 2 and 3 ITS conversion submittal:

TSTFs Approved - Not Adopting TSTF Description of TSTF Reason for Not Adopting TSTF-373-A, Increase CIV Completion Time in accordance with SONGS has approved, plant specific Rev. 2 CE-NPSD-1168 Completion Times.

TSTF-427-A, Allowance for Non Technical Specification Barrier SCE has decided not to incorporate Rev. 2 Degradation on Supported System OPERABILITY. this new LCO 3.0.9 allowance.

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