ML20198H851

Proposed Tech Specs 3.5.2 Re Extension of Completion Time for Low Pressure Safety Injection Train

ML20198H851
Person / Time
Site:	San Onofre
Issue date:	01/09/1998
From:	SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20198H826	List: ML20198H821 ML20198H838 ML20198H851
References
NUDOCS 9801130408
Download: ML20198H851 (35)

Text

. - .

.p .

g[.  ;[-

- ECCS-Operating -

. 3.5.2 Y . V w 3.5.2 fECCS- Operating . .

sLC003.512': Two ECCS trains shall be' OPERABLE.

i ,

~ APPLICABILITY:: ' MODES --

1 and .2,.-

MODE 3 with pressurizer pressure a 400' psia, 1

t ACTIONS CONDITION' REQUIRED ACTION COMPLETION TIME o * 'A. One or more trains- A .1 - Restore train (s) to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. ' OPERABLE status.

MD i

- At least 100% of the t- ECCS flow equivalent to a single OPERABLE ECCS- train available.

,E B..,sRequired Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to-

< 400 psia.

I .

i 980113040e 9e0109 PDR ADOCK 05000361 P PDR 3.5-4

SANONOFRE--UNIT 2; Amendment No. 127 y ,, . , , , , .

.m. , s. ., ,

s'J .' d ECCS -Operating  :

B 1.5.2 4

< -i BASES:

1 APPLICABILITY b'ased on full power' operation. Although reduced power would . ,

-(continued)1  : not require- the same level of- performance,: the accident 1 analysis does not provide for reduced cooling requirements  :

in the lower MODES. .The HPSI pump-performance'is based on ,

the small break.LOCA, which establishes _ the pump performance:

curve and has less dependence on power. The charging pump i performance requirements are based on a small break LOCA. l The requirements of MODES 2, and 3 with RCS pressure

= 400 psia, are bounded by the MODE 1 analysis.  !

The ECCS functional requirements of MODE 3, with RCS _

pressure < 400 psia, and MODE 4 are described in LC0 3.5.3, "ECCS - Shutdown . "

in MODES 5 and 6,. unit conditions are such that the probability of'an event requiring ECCS injection is extremely low, Core cooling requirements in MODE 5 are addressed by LC0 3.4.7, "RCS Loops MODE.5, Loops Filled,"

and LC0 3.4,8, "RCS Loops-MODE 5,LLoops Not Filled."

HODE 6 core cooling requirements.are addressed by LCO 3.9.4,.

" Shutdown Cooling (SDC) and Coolant Circulation-High Water--

Level," and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."

ACTIONS ad if one or more trains are inoperable. and at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC study (Ref. 4) using a reliability

. evaluation and is a reasonable amount of time to effect many repairs.

An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not .apable of performing their design function, or if supporting systems are not available.

c The.LC0 requires the OPERABILITY of a number of independent subsystems.- Due to the redundancy of trains and the

-diversity of subsystems', the 'inoperability of: one- component (continued)

SAN ON0FRE ; UNIT 2- 'B 3.5-16 Amendment No. 127 y  %

,. g..

ECCS-Operating B 3.5.2 BASES ACTIONS eu.1(continued) in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of this Condition is to maintain a combination of OPfRABLE equipment such that 100% of the ECCS flow equivalent to 100%

of a sirgle OPERABLE _ train remains available. This allows increased ficxibility in plant _ operations when components in opposite trains are inoperable.

An event accompanied by a loss of offsite power and the failure of an emergency DG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify c'ntinued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Reference 5 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses. Therefore, LC0 3.0.3 must be immediately entered.

B.1 and B.2 If the inoperable train cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. lo achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to

< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times dre reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems.

. SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS SR 3.5.2.1 verification of proper valve position ensures that .the flow path from the ECCS pumps to the RCS is (continucd)

SAN ONOFRE- UNIT 2 B 3.5-17 Amendment Nu. 127

.e' 1.* ,

~

l ECCS-Operating B 3.5.2

. BASES.

SURVEILLANCE - SR 3.5.2.1 and 3.5.2.2 (continued)

REQUIREMENTS' i maintained. Misalignment-of these valves could' render both +

ECCS trains inoperable. Securing these valv_es in position l by removing power or by key locking the control in the -

correct position ensures that the-valves cannot be inadvertently misaligned or change position as the result of-an active failure. These valves are of the type described in Reference 5, which can disable the function of both ECCS-trains and invalidate the accident analysis. SR 3.5.2.2 verification of the proper positions of the Containment

- Emergency Sumn.irolation valves and ECCS pumps / containment spray pumps miniflow valves ensures that ECCS operability and containment integrity are maintained. Securing these

, valves in position with power available will provide  ?

additional assurance that these valves will operate on-a RAS.- A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.

SR 3.5.2 1 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or etherwise secured in position, -since these valves were verified to'be in the correct position 4

prior to locking, sealing, or securing. A valve that receives-an actuation signal is allowed to be in a nonaccident position provided the valve automatically 4

repositions within the' proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves-verification that those values capable of being mispositioned are in the correct position.

The 31 day Frequency is appropriate because the valves are

- operated under procedural control and an improper valve position-would only affect. a single-train. _This Frequency has been shown- to be acceptable through -operating experience.

~

(continued)

SAN ONOFRE--UNIT 2. B 3.5-18 Amenc ;nt No.127

-k-

+pr --

g 3 p

ECCS-Operating B 3.5.2

-BASES SURVEILLANCE SR 3.5.2.4 REQUIREMENTS (continued) With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode.. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps.to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS pon demand. This will also prevent water hammer, pump vitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day Frequency takes into consideration the gcadual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.

SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one noint of the pump characteristic curve. This verifies botn that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than o'. equal to the performance assumed in the unit safety analysis. SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and Frequencies necessary to satisfy the requirements.

SR 3.5.2.6 Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A quarterly Frequency for such tests is a Code requirement.

Such inservice inspections detect component degradation and incipient failures. For positive displacement charging

_ pumpsSection XI of the ASME Code allows an alternate testing for_ design flow only.

(continued)

SAN ON0FRE--UNIT 2 B 3.5-19 Amendment No. 127

.n'- :o' ECCS-Operating 8 3.5.2 BASES =

SURVEILLANCE- SR 3.5.2.7. SR 3.5.2,8. and SR 3.5.2.9 REQUIREMENTS 1

=(continued)- These SRs demonstrate that each automatic ECCS valve actuates to the _ required position on an_ actual or simulated SIAS and/or an actual- or. simulated RAS- as appropriate to each valve, that-each ECCS pump starts on receipt of-an actual or simulated SIAS, and that the LPSI pumps stop on-receipt 'of an actual or simulated RAS. The 24' month' Frequency is based on the need to perform these-Surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the The Surveillances were performed with the reactor at-power.

24_ month Frequency is also acceptable based on consideration of the dedgn reliability (and confirming operating of.the equipment. The actuation logic is tested experience) as part.of t he Engineered Safety Feature Actuation System (ESFAS) testing,-and equipment performance is monitored as part of the Inservice Testing Program.

-SR 3.5.2.10-Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition.

-The 24 month Frequency is based-on the need to perform this Surveillance under the conditions that apply during an outage, on the need to have access-to the location. This frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.

REFERENCES- 1. 10 CFR 50, Appendix A, GDC 35,

2. 10 CFR 50.46.

3. UFSAR, Section 6.3.

4. NRC 11emorandum to V. _Stello, Jr., from R. L. Baer,

" Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

5. IE Information Notice No. 87-01, January 6, 1987.

i B 3.5-20 Amendment No. 127 May 2, 1997  :

SAN ONOFRE--UNIT:2-~

( o -; ' *- "

l Procedures, Progra:s, and Manuals 5.5 l

5.5 Procedures, Programs, and Manuals:

-)

I 5.5.2.12- Ventilation: Filter Testing Program:(VFTP) (continued)-

Tht provisions of Technical-Specification Surveillance Requirement 13.0.2:and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VETP test frequencies.

5.5.2.13 Diesel _ fuel 011= Testing-Program- -i

-I

This program implements required testing-of both new fuel oil and  !

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

1

a. At lease'once'per 92 days and from new fuel oil prior to addition .to the storageLtanks by verifying that a -san.ple obtained in accordance with ASTM-04057-81 has a water and ,

sediment content of_ less_ than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, -

and a kinematic viscosity 9 40 C of-greater than or equal to

-1.9 but less than or equal to 4.1 when tested in accordance with ASTM 0975-81. <

b. At'least' once every 92 days by obtaining a sample of fuel oil -)

in accordance with-ASTM D4057-81 cnd verifying that particulate. contamination is less than 10mg/ liter when chec;.ed in accordance with ASTM-D2276-83, Method A.

d 1

V 4

f SAN'ON0fRE--UNIT 2l 5.0-20' Amendment No. 4B7,130

__ u- . = . __ _ _

c, ' c' c l

t f

r ATTACilMENT "B" EXISTING TECHNICAL SPECIFICATIONS UNIT 3

• < a ~ r .- ,_

o '

t ECCS-Operating 3.5.2

~ 3.5.2 ECCS -Operating LCO. 3.5.2- Two ECCS trains shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

. MODE 3 with pressurizer pressure a 400 psia.

ACTIONS CONDITION' REQUIRED ACTION COMPLETION TIME ~

A. One or more trains A.1 Restoretrain(s)to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.

AND At least 100% of the ECCS_ flow equivalent to a single OPERABLE ECCS train available.

B. Required Action and B.1 Be in MODE 3, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

' associated Completion Time not mat. AND B.2. Reduce pressurizer .12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to

< 400 psia.

L

SAN ON0fRE; UNIT 3: 3.5 Amendment No, 116-

+ , , ., .:.,, -_a- . . - . . a, -

ECCS -Operat ing B 3.5.2 BASES APPLICABillTY based on full power operation. Although reduced power would (continued) not require tne same level of performance, the accident l analysis doet not provide for reduced cooling requirements in the lower MODES. The HPSI pump performance is based on l I

the small break LOCA, which establishes the pump performance i curve and has less dependence on power. The charging pump performance requirements are based on a small break LOCA. '

1he requirements of MODES 2, and 3 with RCS pressure e 400 psia, are bounded by the MODE I analysis. l The ECCS functional requirements of MODE 3, with RCS pressure < 400 psia, and MODE 4 are described in LC0 3.5.3, "ELCS - Shu tdown . " -

In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops MODE 5, Loops filled,"

and LCO 3.4.8, "RCS Loops H0DE 5, Loops Not filled."

MODE 6 core cooling requirements are addressed by LC0 3.9.4,

" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level." and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."

ACTIONS M If one or more trains are inoperable and at least 100'r. of the ECCS flow equivalent to a single OPERABLE ECCS train is available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC study (Ref. 4) using a reliability evaluation and is a reasonable amount of time to effect many repairs.

An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not capable of performing their design function, or if supporting systems are not available.

The LC0 requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component

-- (continued)

SAN ON0fRE--UNIT 3 8 3.5-16 Amendment No. 116

\ , - -

, {

ECCS-Operating l B 3.5.2  ;

i BASES l f

ACTIONS AJ (continued)  ;

in a train does not reader the ECCS incapable of performing j its function. Neither does the inoperability of two i different components, each in a different train, necessarily  ;

result in a loss of function for the ECCS. The-intent of  !

this Condition is to maintain a combination of OPERABLE l equipment such that 100% of the ECCS flow equivalent to 100%  !

of a single OPERABLE train remains available. This allows  !

increased flexibility. in plant operations when components in 4 opposite trains are inoperable. l

-An event accompanied by a loss of offsite power and the .  !

failure-of.an emergency DG can disable one ECCS train until l power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is  :

sufficiently small to justify continued operation for  ;

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Reference 5 describes situations in which one component,  ;

such as a shutdown cooling total flow control valve, can 4 disable-both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a j single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be immediately entered, r B.1 and 8.2 -

If the ino)erable train cannot be restored to OPERABLE  :

status witiin the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to

< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the ,

required unit conditions from full power in an orderly manner and:without challenging unit systems.

SURVEILLANCE .SR 3.5.2.1 and 3.5.2.2

-REQUIREMENTS' SR 3.5.2.1 verification of proper valve position ensures ,

that the flow path from the ECCS pumps to the RCS is >

(continued) [

SAN OM0fRE- UNIT:3: B 3.5 17 Amendment No, 116

. .. -- - .. , . ~ . . , .- , -- , - . - , - - - . - - -

d o ECCS-Operating l B 3.5.2 l BASES SVRVEILLANCE SR 3.5.7.1 and 3.5.2.2 (continued)

REQUIREMENTS maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removing power or by key locking the control in the correct position ensures that the valves cannot be inadvertently misaligned or change position as the result of  ;

an active failure. 1hese valves are of the type described  :

in Reference 5, which can disable the function of both [CCS trains and invalidate the accident analysis. SR 3.5.2.2 verification of the proper positions of the Containment Emergency Sump isolation valves and ECCS pumps / containment spray pumps miniflow valves ensures that ECCS operability and containment integrity are maintained. Securing these valves in position with power available will provide additional assurance thst these valves will operate on a RAS. A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frecuency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.

SR 3.5.2.3  :

Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day frequency is appropriate because the valves are operated under procedural control and an improper valve

)osition would only affect a single train. This frequency las been shown to be acceptable through operating experience.

(continued)

SAN ON0FRE--UNIT 3 8 3.5 18 Amendment No. 116

.' e' )

ECCS -Operating  ;

B 3.5.2 BASES '

SURVEILLANCE SR 3.5.2.4 REQUIREMENTS (continued) With the exception of systems in operation, the ECCS aumps are normally in a standby, nonoperating mode. As suc1, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. 1his will also prevent water hammer, pump

<:avitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural contiois governing system operation.

SR 3.5.2.5 periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

SR 3.5.2 5 Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A quarterly frequency for such tests is a Code requirement.

Such inservice inspections detect component degradation and incipient failures. For positive displacement charging pumpsSection XI of the ASME Code allows an alternate testing for design flow only.

(continued)

SAN ON0fRE--UNIT 3 B 3.5-19 Amendment No, 116

y'

}

ECCS-Operating  !

B 3.5.2  !

~l BASES j i:

SURVEILLANCE SR 3.5 J.7. SR- 3.5.2.8. and SR 3.5.2.9- ,

REQUIREMENTS i (continued) These SRs demonstrate.that each automatic ECCS valve i actuates to the required position on an actual or simulated  !

~SIAS and/or an actual or simulated RAS as appropriate to l each valve that each ECCS pump starts on receipt of an  ;

actual or simulated SIAS, Lnd that the LPSI pumps stop on i

receipt of an actual or simulated RAS. The 24 month i frequency is based on the need to perform these i Surveillances under the conditions that apply during a plant l outage and the potential = for unplanned transients if the ,

Surveillances were performed with the reactor at power. The j 24 month frequency is also acceptable based on consideration l of the design reliability (and confirming operating i experience) of-the equipment. The actuation logic is tested  ;

as-part of the Engineered Safety feature Actuation System i f

(ESfAS) testing, and equipment performance is monitored as ,

part of the Inservice Testing Program. _

l l

i SR 3.5.2.10 .

f Periodic inspection of the containment sump ensures that it  !

is unrestricted and stays in proper operating condition.  ;

The 24 month frequency is based on the need to perform this Surveillance under the conditions that apply during an i outage. on the need to have access to the location. This frequency is sufficient to detect abnormal degradation and  :

is confirmed by operating experience.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 35,

2. 10 CFR 50.46.  !

3. UfSAR, Section 6.3.

l 4 NRC Memorandum to V. Stello, Jr., from R. L. Baer,  !

" Recommended Interim Revisions to LCOs for ECCS  :

Components,' December 1, 1975. j

5. IE.Information Notice No. 87 01, ,lanuary 6, 1987.

j SAN'ON0fRE- UNIT 3' B:3.5 20 Amendment No.1116 May 2, 1997

-.h-

,.s- , ,..-.- -

, ..~ . ,.,r_-_ _ ., _, __ , _ , ~ . _ ,,-. .. . _ _ . . _ - , _ . . -

o' o

Procedures, Progra;s, and Manuals 5.5 5.5 Procedures, Programs, and Manuals 5.5.2.12 Ventilation filter Testing Program (VfTP) (continued) .

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

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

establish the following:

a. At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with AS1M 04057 81 has a water and sediment content of-less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM 0975 81.

b. At least once every 92 days by obtaining a sample of fuel oil in accordance with ASIM 04057-81 and verifying that particulate contamination is less than 10mg/ liter when checked in accordance with ASTM D2276 83, Method A.

I i

SAN ON0fRE--UNIT 3 5.0 20 Amendment No. H 6,119

T a* c' ATTACHMENT "C" PROPOSED SPECIFICATIONS UNIT 2 I

f r

i a

B 7

o '. .e l

ECCS-Operating- i 3.5.2 '

e i 3.5.2 ECCS-Operating LCO 3.5.2 Two ECCS tr' ains shall be OPERABLE.

APPLICABillTY:- MODES 1 and 2, MODE 3 with pressurizer pressure t 400 psia.

AC110NS.

CONDITION REQUIRED ACTION COMPLETION TIME  :

A.-E 0nelLP51 subtra'n 7(days

~ A.l!J"- 1 Restore: subtrain'tto

" ' ~ ~

" linoperable..; "0PERA8LE;statusI^

A A-

-B; One or more ECCS B.1 RestoreECCStrain(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> trains inoperable due to OPERABLE" status. 1 to reason (s) other than Condition A~."

MQ .

, At least 100% of the  !

L ECCS flow equivalent

• to a single OPERABLE ECCS train available.  :

B B C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of' Condition A or

' ~~ '

MQ R not met; B C.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to

- < 400 psia.

L G

' SAN ON0fRE l UNITL2: 3.5-4 Amendment No. +N s

, , - . - , y . - - . .c ,,,, - , . - - - . -e-. - -

4 ,

ECCS-Operating B 3.5.2 BASES APPLICABIL11Y- based on full power operation. Although reduced power would (continued) not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The HPSI pump performance is based on the small break LOCA, which establishes the pump performance curve and has less dependence on power. The charging pump performance requirements are based on a small break LOCA.

The requirements of MODES 2, and 3 with RCS pressure a 400 psia, are bounded by the MODE I analysis.

The ECCS functional requirements of MODE 3, with RCS pressure < 400 psia, and MODE 4 are described in LCO 3.5.3, "ECCS - Shu tdown. "

in MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops MODE 5, Loops Filled,"

and LCO 3.4.8, "RCS Loops MODE 5, Loops Not filled."

MODE 6 core cooling requirements are addressed by LC0 3.9.4,

" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level," and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water level."

ACTIONS A.lLand Bil H-en cr =re-tre4n; cre inepecable-end-at-least-100%-ef the4GG44ew-equivalent-tc :-; ingle-OPERABLE-4CCS train-4s ava44ebler -1he in;per ble-eemponent+-must be reisened-te OPERABLE-steles-w& thin 72 h;urs. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Complet4en 14= i; b :cd cr, en NRC :tudy (Rei .1)-us4ng a rc44eb44441 eve 1*at4en-and-4 re::Onable :=;nt-+f-t4me-to cf fec4-many repale&r An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are-not capable of performing their design function, or if supporting systems are not available.

The LC0 requires the OPERABillTY of a number of independent subsystems. Due to the redundancy of traits and the

-diversity of subsystems, the inoperability of one component (continued)

SAN ON0FRE UNIT ? .B 3.5-16 Amendment No. 4W -

ECCS -Operating B 3.5.2 BASES l ACTIONS A.l'and Bil (continued) in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of (Ms-Cedit4on-4s each of Condition' A and Condition B is to maintain a combination'of OPERABLE equipment'such that'100%

of the ECCS flow equivalent to 100% of a single OPERABLE ,

train remains available. This allows increased flexibility in plant operations when components in opposite trains are innperable.

Each of Condition A and Condition B lncludes a combination of OPERABLE equipment lsuch that at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS _ train remains available.

Condition A addresses the specific condition ~where the only affected ECCS subsystem is a single LPSI subtrain. The availability of a least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train. is implicit in the definition of Condition A.

If LCO 3.5.2 requirements are not met due only to the existence of Condition A, then the inoperable LPSI subtrain components must be returned to OPERABLE status within 7 days of discovery of Condition A. A Configuration Risk Management Program (CRMP) defined in Administrative Controls L Ig,1 section 5.5.2.14 is implemented in the event of Condition A.-

This 7-day Completion Time is based on the findings of the deterministic and probabilistic analysis that are discussed in Reference 6. Seven days is a reasonable amount of time to perform many corrective and preventative maintenance items on_the affected LPSI subtrain. - Reference 6 concluded that the overall risk impact of this Completion Time was either risk beneficial or risk. neutral.

Condition B addresses'other scenarios where the availability of at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train exists but the full requirements of LCO 3.5.2 are not met. If Condition B exists, then inoperable components must be restored such that Condition b does not exist within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of discovery. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC reliability study (Ref. 4) and is a reasonable amount of time to effect many repairs.

(continued)

SAN ONOFRE--UNIT 2 B 3.5-17 Amendment No. W

.. . l ECCS-Op2 rating ,l B 3.5.2

-BASES

~

l ACT10h5 A.1 and'3:1 (continued) l An event accompanied by a loss of offsite power and the l failure of an emergency DG can disable one ECCS train until  ;

power is restored. A reliability analysis (Ref. 4) has  !

shown that the impact with one full ECCS train inoperable is i sufficiently small to justify continued operation for  :

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

l Reference 5 describes situations in which one component,  !

such as a shutdown cooling total flow control valve, can  ;

disable both ECCS trains. With one or more components '

inoperable, such that 100% of the equivalent flow to a 1 single OPERABLE ECCS t+a4*-is not available, the facility is in a condition outside the accident analyses. Theref;r:, in  !

suchTarsituationiLC03.0.3mustbeimmediatelyentered.

3 i B B C.1 and C.2 t If the ino)erable train cannot be restored to OPERABLE  !

status wit 11n the associated Completion Time, the plant must 1 be brought to a MODE in which the LCO does not apply. To .  ;

_ achieve this status, the plant must be brought to at least-

~

MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to

< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times '

are reasonable, based on operating experience, to reach the  ;

required unit conditions from full power in an orderly manner and without challenging unit systems.

-SURVEILLANCE- SR 3. 5. 2._L and 3. 5. 2. 2 REQUIREMENTS- .

SR 3.5.2.1 verification of proper valve position ensures  ;

that the flow path from the ECCS pumps to the RCS-is ,

maintained, iiisalignment of these valves could render both i ECCS trains: inoperable. Securing these valves in position i by removing power or by key locking the control in the 1 correct position Snsures that the valves cannot be- >

inadvertertly misaligned or change position as the result of an active failure. These valves are of the type described in Reference 5,'which can disable the function of both-ECCS l

-(continued)

?

SAN 10N0fRE--UNIT _2' B 3.5 18. Amendment No. W  ;

, ,- ,_i,,..-e -,.,y . . . , . o y __., . ,. ..,__...,,...1-.-,.. ~ .+ M - ,

o ECCS-Operating  !

B 3.5.2 l

BASES  !

1 SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 (continued) i REQUIREMENTS trains and invalidate the accident analysis. SR 3.5.2.2 verification of the proper positions of the Containment j Emergency Sump isolation valves and ECCS pumps / containment  !

spray pumps miniflow. valves ensures that ECCS operability and containment integrity are maintained. Securing these .

valves in position with power available will provide i additional assurance that these valves will operate on a  ;

RAS. A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency is considered reasonable in view  ;

of other administrative controls ensuring that a f mispositioned valve is an unlikely possibility. l SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides i t

assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position  :

prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a '

nonaccident position provided the valve automatically repositions within the proper stroke time. This ,

Surveillance does not require any testing or valve 7 manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position, t The 31 day frequency is appropriate because the valves are operated under procedural control and an improper valve l Josition would only affect a single train. This frequency  ;

las been shown to be acceptable through operating l experience.

.(coatinued)

SAN ON0fRE--UNIT:2 B 3.5-19 Amendment No. 4W >

, __a.._ . _.___._ __ _ _ - _._ . . . . . . _ . . . _

- - - . - . _. . .. . - - - - _ . . - - - - . - - - ~ . - . - . _ - . _ .

ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4  !

REQUIREMENTS l (continued) With the exception of systems in operation, the ECCS aumps  :

are normally in a standby, nonoperating mode. As suc1, flow l path piping has the potential to develop voids and pockets  !

of entrained gases. Maintaining the piping from the ECCS t pumps to the RCS full of water ensures that the system will perform properly.. injecting its full capacity into the RCS l upon demand. This will also prevent water hammer, pump i cavitation,andpumpingofnoncondensiblegas(e.g., air,  !

nitrogen, or hydrogen) into tiie reactor vessel following an SIAS or during SDC. The 31 day frequency takes into t consideration the gradual nature of gas accumulation in the t ECCS piping and the adequacy of--the procedural controls-governing system operation.

SR 3.S.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other ,

hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at-only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pum) baseline performance and that the performance at t1e test flow is greater than or equal to the  :

performance assumed in the unit safety analysis. SRs are i specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements. l l

SR 3.5.2.6 ,

i Discharge head at design flow is a normal test of charging  ;

pump performance required by Section XI of the ASME Code. A >

quarterly frequency for such tests is a Code requirement.

Such inservice inspections. detect component degradation and  :

+

incipient failures.- For positive displacement charging pumpsSection XI of the ASME Code allows an alternate ,

testing for design flow only.

(continued) f SAN ON0fRE--UNIT 2 8 3.5-20 Amendment No. W e p . e r- g--+9 v v g pp., y-

• y..,4,, g g 4,- .gpv gg g g wpp-i -veg w + g yy-y.-- ---sq,,-g.,yrw-ew y m- p +- y-Uw--9 --v"'

-. ,. -_..._ _ _ _...__- _-___ _ _ _ _. _ . { i ECCS-Operating  !

8 3.5.2 i

.f BASES  !

SURVEILLANCE SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 i REQUIREMENTS (continued) These SRs demonstrate that each automatic ECCS valve _

- actuates to the required position on an actual or simulated .,

SIAS and/or an actual or simulated RAS as appropriate to  ;

each valve, that each ECCS pump starts on receipt of an  !

actual or simulated SIAS, and that the (PSI pumps stop on  !

receipt of an actual or simulated RAS. The 24 month- l Frequency is based on the need to perform these  !

Surveillances under the conditions that apply during a1 plant ,

outage and the potential for unplanned transients if. the  ;

Surveillances were performed with the reactor at power. The  ;

24 month frequency is also acceptable based on consideration  ;

of the design reliability (and confirming operating r experience)oftheequipment. The actuation logic is tested as part of the Engineered Safety feature Actuation System ,

(ESFAS) testing, and equipment performance is monitored as  :

part of-the inservice Testing Program, q SR 3.5.2.10 Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition. l The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during an- '

outage, on the need to have access to the location. This frequency is sufficient to detect abnormal degradation and is confirmed by operating experience. ,

~

REFERENCES 1. 10 CFR 50, Appendix A, GDC 35,

2. 10 CFR 50.46. .

3. UFSAR, Section 6.3.

4. NRC Memorandum to V. Stello, Jr., from R. L. Baer,  ;

" Recommended Interim Revisions to-LCOs for ECCS t Components," December 1, 1975.  !

5. -lE information Notice No. 87-01, January 6, 1987. [

6b -CE NPS0e995N"CEOG Joint' Applications" Report ~for' Low

" Pressure Safety;lnjection_ System A0TEExter.sion,";May .

1995.-  ;

a

' SAN ON0fRE--UNIT 2 8;3.5-20a Amendment No.. M7-hy 2, '997 7

, ^

pm.-c. ,.- g...g4.gyw-p. .y-pp.,9,- -% d --, y ggyw-gws,- t- -*ye- ee y .yyew g -ypah ewm, y .p.pvw-g-we.r y g - eg ye3

o' .

Pre;cedures Prograns, and Manuals 5.5 5.5 Procedures Programs, and Manuals 5.5.2.12 Ventilation filter Testing Program (VF1P) (continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the Vf1P test frequencies.

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

a. At least once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057 81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity @ 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM D975 81.

b. At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM D4057-81 and verifying that particulate contamination is less than 10mg/ liter when checked in accordance with ASIM D2276-83, Method A.

5.5.2.14 Configuration . Risk Management Program (CRMP)

The_ Configuration ~ Risk Management Program (CRMP) provides a pt M eduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk informed Completion Time has been granted. -The program shall include the followir,g elements:

a. Provisions for the control and implementation of a level 1 at suffl powet internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b. ' Provisions'for performing an assessment prior to entering the LC0 Condition for preplanned activities:

~

c. Provisions for: performing an assessment after entering the LC0 Cendition for unplanned entry.into the LC0 Condition.

(continued)

SAN ON0fRE--UNIT 2 5.0-20 Amendment No. WhMO

. [

i Procedures, Programs, and Manuals -!

5.5 i

' 5.5 Procedures, Programs, and Manuals l

?

5;5.2.147 ConfigurationRiskManagement;Ptogram':(CRMP)lc(Continuad) lt di ' Provisions ~ for assessing ~ the need for' additional ' actions after I the discovery of; additionalhuipment out of. service '

i conditions ~while in the LCO Condition. i S.gg.1 e

e. Provisions:for considering other~ applicable risk'significant  ;

contributors such as Level 2 issues,'and external events,-

qualitatively or; quantitatively. i r

I 4

i 4-SAN ONGFRE--UNIT 2 5;0 20a- Amendment No. 3HTM0 1

. . i l

)

I 1

i b

l I

i i

ATTACHMENT "0" f PROPOSLO SPECIFICATIONS i UNIT 3  !

5 i

e P

i s

L

7

.,i ( ' <

? ECCS-Operatin 3.5.

a 3.5.21 - ECCS -Operatit g LCO' 3.5.2' Two ECCS trains, shall be OPERABLE.

AEPLICABILITY: MODES 1 and O.

MODE 3 with pressurizer pressure a 400 psia.

ACTIONS _

CONDITION REQUIRED ACTION COMPLETION TIME

..m .

t

' LAs'"q 0ile;LPSlishbtraivi A.!W

" ~ " "

Rnstore'subtraln'Jto '~7' day ~s jyoperab. leg ~~~ '0PER,ABLD status (

A A-

, D. Ona or neore LCC;S - B.1

~

RestoreECCStrain(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> trains ino.e able dig to OPERABLE' status, to: ressan(s)"otlierj ~

thenfCondit1,ong l AND At ledst 100% of the -

ECCS flow equivalent to'a single OPERABLE ECCS train available.

8 8 C. Required Action and C.1 Bs in MODE 3. 6 tiours associated Completion TimeofCondjtionlV~or ~ ^

AND B not" met'. B C.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to

< 400 psia, i t-i

. SAN'ONOFRE ; UNITi 3' -

-3.5 4 Amendment No. H4

, + - ,

ECCS-Operating B 3.5.2 BASES APPLICABILITY based on full power operation. Although reduced power would (continued) not require the same level of performance, the accident analysis does not provide for reduced cooling requirements

-in the lower MODES. The HPSI pump performance is based on the small break LOCA, which establishes the pump performance curve and has less dependence on power. The charging pump performance requirements-are based on a small break 1.0CA.

The requirements of MODES 2, and 3 with RCS pressure a 400 psia, are bounded by the MODE I analysis.

The ECCS functional requirements of MODE 3, with RCS pressure < 400 psia, and MODE 4 are described in LC0 3.6.3, "ECCS - $hutdown. "

In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops MODE 5, Loops filled,"

and LCO 3.4.8, "RCS Loops MODE 5, Loops Not Filled."

MODE 6 core cooling requirements are addressed by LCO 3.9.4,

" Shutdown Cooling (SDC) and Coolant Circulation ~High Water Level," and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant-Circulation-f ow Water Level."

l ACTIONS A.1 and B.1 If := :,t Or: trein: cre (=per ble and :t4:05t 100% of the ECCS-flew equ Wetent t  : :ing!: O'ERABLE ECCS train is eveH+h10, the i ne:reble : =

OPEP/SLT ;4-aws-wf4hin 2 h:;p:=nt: r:. The-7me;t- be retur=d te M :ar C::-10 tion T4:e 1 b=ed en :n NRC :tudy-(hf. -4) u;hwf-c re!!:bility eyeluction =d i: : re souble :=ent- of t he t0 effect ==y repeleer An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. -The individual components are inoperab12 if they are not capable of performing their design function, or if supporting systems are not available.

The LCO requires the OPERABILITY-of a numbero' f independent' subsystems- . Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component (continued)

. SAN _ON0fRE -UNIT 3 B 3.5-16 Amendment No. 'H4

,, ,. ( o ECCS-Operating B 3.5.2 BASES.

ACTIONS 6.l!And11(continued) in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of G4s C=dHunde-eachief ConditionJA and Condition Blis to maintain a combination ^of OPERABLE equipment'such that~100%

of the ECCS florequivalent to 100% of a-single OPERABLE train remains available. This allows increased flexibility in p'lant operations when components in opposite trains are inoperable.

Each"ef, Condition A'andtCondition 8 includes a? combination of'0PERA88 E equipment such th'at at least:1005;of the ECCS flew equivalent.tofe single OPERABLE ECCS train' remains ~~

~

available.

Condition Ar addresses?thefspecific' condition ~where the only_

affected ECCSLsubsystem is a: single LPS!;subtrain.:D The ~

availabilitf of;a;leastt100% of!the (CCS flow equivalent?to a' single OPERABLE ECCS train'islimpilcitiin the definition

~ ' '" '

of; Condition _A.

IfLLCO 3;5.tirequirements;are:notcmet?dueDonifto:the existence /of; Condition A,ethen;the inoperable LPSI.subtrain components must betreturned to:0PERABLE status within 7: days of discovery of: Condition:AL A Configuration Risk ~~~ " " ~

Mana$ement:Pr)4:is:ir;,lements L N.1 in thelevent of Condition A.erami(C sect un 5.5.2 This 7-day Completion; Time;is basad on the findings!of the deterministic 1and probabilistic_-analysis;thatlare discussed in Reference'6.1 1Seven daysiis a reasonableLamounttof time' to' perform many corrective and7 preventative maintenance ~~

items.on the affected LPSIJsubtrain.7-Reference 6 concluded that the overall risk 11mpact of thistCompletioniTimeLwas eitherrisk-beneficiaVorrisk: neutral.

Condition;8Tasdressesiother scenarios:whereTthe availabilit of at least 100% of the?ECCSlflowTe OPERABLE ECCS train:fullcroquirementsexists;but;the of LC0quivalentit 3.5.2 are not'meti Lif Condition B' exists, theniinoperable componentsLmust be: restored ,such;that! Condition 8,does not exist;within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of; discovery.- jThe-72 hour Completion line;istbased on an=NRC reliability? study.(Ref.J4)Tand is;a reasonabl e t amount ( o f t i me to; e f fect :many, repa i_rs !

(contiaued)

SAN ON0fRE- UNIT 3 B 3.5 17 Amendment No. 4M

i

,; s ECCS-Operating  !

B 3.5.4 j BASES

, ACTIONS A.P and's.1 (continued)

An event accompanied by a loss of offsite power and the failure of an emer power is restored.gency DC can disable one ECCS train until Areliabilityanalysis(Ref.4)has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Reference 5 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a single.0PERABLE ECCS (n k-is not available, the facility is in a condition outside the accident analyses, h erefer , In suchlaisituation, LCO 3.0.3 must be immediately entered.

B' B C.1 and C.2 If the ino)erable train cannot be restored to OPERABLE status wit 1tn the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To' achieve this status, the plant mus', be brought to at 1 cast MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to

, -< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS SR 3.5.2.1 verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both

'ECCS trains inoperable. Securing these valves in position by removing power or by key locking the control in the correct position ensures that the' valves cannot be inadvertently misaligned or change position as the result of an active failure. These valves are of the type described in Reference 5,- which can disable the-function of both ECCS (continued)

SAN ON0FRE UNIT 3 8 3.5 18- Amendment No. 1%

l

,.,_,o.

ECCS -Operating B 3.5.2 BASES SURVEllLANCE. SR 3.5.2.1 and 3.5.2.2 (continued)

-REQUIREMENTS trains and invalidate the accident analysis. SR 3.5.2.2 verification of the proper positions of the Containment Emergency Sump isolation valves and ECCS pumps / containment spray pumps miniflow valves ensures that :CCS operability and containment itetegrity are maintained. Securing these valves in position with power available will provide additional-assurance that these valves will operate on a RAS. .A 12-hour frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.

SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically

, repositions within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day frequency is appropriate because the valves are operated under proc 9 dural control and an improper valve position would only affect a single train. This frequency has been shown to be acceptable through operating experience.

(continued)

SAN ONOFRE iUNIT- 3 .B 3.5-19 Amendment No. 46

I a 'e 'o ECCS-Operating B 3.5.2 BASES j

SVRVEILLANCE SR 3.5.2.4  !

REQUIREMENTS l

(continued) With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the of entrained gases. potential Maintaining to develop voids the piping fromand pockets the ECCS pumps to the RCS full'of water ensures that the system will l perform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, )

cavitation, and pumping of noncondensible gas (e.g. pump, air, i nitrogen, or hydrogen) into the reactor vessel following an i 514S or during SDC. The 31 day frequency takes into 4 consideration the gradual nature of gas accumulation in the '

ECCS piping and the adequacy of the procedural controls governing system operation.

r SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross i degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at- only one point of the pump characteristic curve. This verifies both that the  :

measured performance is within an acceptable tolerance of i the original puma baseline performance and that the l

performance at tile test flow is greater than or equal to the  ;

performance assumed in the unit safety analysis. SRs are  ;

specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code. Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements, i MS.ld Discharge head at design flow is a normal test of charging pump performance required by Section XI of- the ASME Code. A quarterly frequency for such tests is a Code requirement.

Such inservice inspections detect-component degradation and incipient failures. -For positive displacement charging pumps-Section XI of the ASME Code allows an alternate testing for design flow only.

(continued)

SAN ONOFRE--UNIT 3- B 3.5-20 Amendment No. H4

' , < , * *o o ECCS -Operating .

B 3.5.2 BASE $

SURVEILLANCE SR 3.5.2.7. SR- 3.5.2.8. and SR 3.5.2.9 REQUIREMENTS (continued) These SRs' demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SIAS and/or an actual or simulated RAS as appropriate to each valve that each ECCS pump starts on receipt of an actual or simulated SIAS, and that the LPSI pumps stop on receipt of an actual or simulated RAS. The 24 month frequency is based on the need to perforrn these

'Surve111ances under the conditions that apply during a plant outage and the potential for unplanned transients if the Surveillances were performed with the reactor at power. The 24 month frequency is also acceptable t; sed on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of tne Engineert.d Safety feature Actuation System (ESFAS) testing, and equipment performance is monitored as part of the Inservice Testing Program.

SR 3.5.2.10 Periodic inspection rf the containment sump ensures that it is unrestricted and stays in proper operating condition.

The 24 month frequency is based on the need to perform this Surveillance under the conditions that apply during an outage. on the need to have access to the location. This frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.

REFERENCES 1. 10 CfR 50, Appendix A, GDC 35,

2. 10 CFR 50.46.

3. UFSAR, Section 6.3.

4. NRC Memorandum to V. Stello, Jr., from R. L. Baer,

" Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

5, IE Information Notice No.~87 01, January 6, 1987.

6.CCE:NPS0;995,2"CEOG' Joint" ApplicationiReport for; Low

~ " Pressure Safety injection System-A0T Extension," May

~

1995.

SAN ON0FRE--UNIT 3 Bf3.5220a Amendment No. -1M Ny 2, 1997

}

. .. t

• Procedures Prograns, and Manuals 5.5 5.5 Procedures, Programs, and Manuals 5.5.2.12 Ventilation filter Testing Program (VfTP) (continued)

The provisions of Technical Specification Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the Vf1P test frequencies.

5.5.2.13 Diesel fuel Oil Testing Program lhis program implements required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards. The purpose of the program i to establish the following:

a. At least once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTH 04057-81 has a water and sediment cohtent of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity (a 40 C of greater thaa or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM 0975 81.

b. At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM 04057-81 and verifying that particulate contamination is less than 10mg/ liter when checked in accordance with ASTM D2276-83, Method A.

Fi.2.14- Configuration Risk Management Program 'CRMP)

The Configuration Risk' Management' Program (CRMP) provides a proceduralized risk-info *med assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed Completion Time has been granted.' The program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at Sq* .1 power internal events PRA informed methodology. The assessment shall be cape.ble of evaluating the applicable plant configuration, b .' - Provisions for performing an' assessment LC0 Condition for preplanned activities, prior'to entering'the

c. Provisions-for performing an assessment after entering'the LCO Condition for unplanned entry into_ the LCO Condition.

(continued)

SAN ON0fRE- UNIT 3 5.0 20 Amendment No. 4%+19

)

o 'o?

Procedures, Programs, and Manuals .

5.5 5.5 Procedures Programs, and Manuals 5.5.2.14: iConfiguratlon'RiskManagement(Program;(CRMP)l;(Continued) d.. Provisions:for assessing;the need'for additional.'~actionst after the~ discovery of additional equipment out of service conditions while in the.:LCO Condition. Lg.1 e,. Provisions for consideringothe blicableTelsk significant contributors such as Level 2 ii ,,jandexternalfevents, qualitatively or quantitatively SAN ONOFRE UNIT 3 5.0-20a Amendment No. M 6T H9 n' .)