ML20199K645

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Proposed Tech Specs 3.5.1,extending Completion Time for Single Inoprable SIT from 1 H to 24 H & Adding New TS 5.5.2.14, Configuration Risk Mgt Program
ML20199K645
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/03/1998
From:
SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20199K618 List:
References
NUDOCS 9802060234
Download: ML20199K645 (31)


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ATTACHMENT "A"-

EXISTING TECHNICAL SPECIflCATIONS UNIT 2-i s

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SITS 3.5.1 3.5 EMERGENCYCORECOOLINGSYSTEMS(ECCS) 3.L.1 Safety injection Tanks (SITS)

LCO 3.5.1 four SITS shall be OPERABLE.

APPLICABILITY:

H0 DES 1 and 2, MODL 3 with pressui r pressure a 715 psia.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TlHE A.

One sit inoperable due A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to coron concentration concentration to not within limits.

within limits, f

l B.

One SIT inoperable for B.1 Restore SIT to I hour reasons other than OPERABLE status.

Condition A.

C.

Required Action and C.1 Be in MODE 3.

f hours associated Completion Time of Condition A AND or B not met.

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

< 715 psia.

D.

Two or more S!Ts D.1 Enter LC0 3.0.3.

Immediately inoperable.

SAN ONOFRE--UNIT 2 3.5-1 Amendment No. 127

~

n

SITS B 3.5.1 BASES ACTIONS M (continued) during reflood concent' rates the boron in the saturated liquid that remains in the core.

In addition, the volume of the SIT is still available for injectien.

Since the boron requirements are based on the average boron concentration of the total volume of three SITS, the consequences are less severe than they would be if an SIT were not available for injection. Thus, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to return the boron i

concentration to within limits.

M If one SIT is inoperable, for a reason other than boron concentration, the SIT must be returned to OPERABLE status i

l within I hour.

In this Condition, the required contents of three SITS cannot be assumed to reach the core during a LOCA. Due to the severity of the consequences should a LOCA occur in these conditions, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time to-open the valve, remove power to the valve, or restore the proper water volume or nitrogen cover pressure ensures that I

prompt action will be taken to return the inoperable accumulator to OPERABLE status. The Completion Time minimizes the exposure of the plant to a LOCA in these conditions.

C.1 and C.2 If the SIT cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE-3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pr<ssurizer pressure reduced to < 715 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 recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems.

(continued)

SAN ONOFRE--UNIT 2-B 3.5-7 Amendment No. 127

SITS j

B 3.5.1 BASES ACTIONS D.d (continued)

If more than one SIT is inoperable, the unit is in a condition outside the accider.+. analyses.

Therefore, LCO 3.0.3 must be entered immediately.

i SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each SIT isolation valve is fully open, as indicated in the control room, ensures that SITS are available for injection and ensures timely discovery if a valve should be partially closed.

If an isolation valve is not fully o)en, the rate of injectica to the RCS would be reduced. Altlough a motor operated valve should not-change position with power removed, a closed valve could result in not meeting accident analysis assumptions. 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 that ensure the unlikelihaod of a mispositioned isolation valve.

SR 3.5.1.2 and SR 3.5.1.3 SIT-borated water volume and nitrogen cover pressure should be verified to be within specified limits every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to ensure adequate injection during a LOCA.

Due to the static design of t'ie SITS, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency usually allows the operator sufficient time to identify changes-bafore the limits are reached. Operating experience has shown this Frequency to be appropriate for early detection and correction of off normal trends.

SR 3.5.1.4 Thirty-one days is reasonable for verification to determine that each SIT's boron concentration is within the required limits, because the static design of the SITS limits the ways in which the concentration can be changed.

The 31 day Frequency is adequate to identify-changes that could occur from mechanisms such as stratification or inleakage. A

) referred method to sampling is permitted for verifying the acron concentration in the SIT after a greater than or equal (contir.ued)

SAN ONOFRE--UNIT 2 B 3.5 8 Amendment No. 127

SITS B 3.5.1 BASES SURVElLLANCE SR 3.5.1.4 (continued)

REQUIREMENTS to 1% volume increase in the SIl not caused by deliberate filling of the SIT from the RWSt. This method requires, within six hours, that the new boron concentration of the affected SIT shall be calculated using the volume change of the SIT and the results of the recent RCS boron analysis.

If the result of the calculation indicates the boron concentration of the affected SIT is within the limits specified in this SR, the surveillance verification is satisfied, it is not necessary to verify boron concentration if the added water is from the RWST, because the water contained in the RWST is within the SIT boron concentration requirements. This is consistent with the recommendations of NUREG-1366 (Ref. 5).

SR

3. 5. l di Verification every 31 days that power is removed from each SIT isolation valve operator when the pressurizer pressure is a 715 psia ensures that an active failure'could not I

result in tha undetected closure of an SIT motor operated isolation valve.

If this were to occur, only two SITS would be available for injection, given a single failure coincident with a LOCA.

Since installation and removal of power to the SIT isolation valve operators is conducted under administrativo control, the 31 day Frequency was chosen to provide additional assurance that power is removed.

This SR allows power to be supplied to the motor operated isolation valves when RCS pressure is < 715 psia, thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during unit startups or shutdowns.

Even with power supplied to the valves, inadvertent closure is prevented by the RCS pressure interlock atsocia+,ed with the valves.

Should closure of a-valve occur in st ate of the-interlock, the SI signal provided to the valves would open a closed valve in the event of a LOCA.

= = = =.

_ _ =. =

(continued)

SAN ON0FRE-UNIT 2 8 3.5-9 Amendment No. 127

SITS c

B 3.5.1 BASES (continued)

REFERENCES 1.

IEEE Standard 279-1971.

2.

UF5AR, Section 6.3.

3.

10 CFR 50.46, 4.

UFSAR, Chapter 15.

5.

NUREG-1366, December 1992.

SAN ON0FRE--UNIT 2 B 3.5-10 Amendment No. 127

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

(continued)

The provisions of Technical Specifiestion Surveillance Requirement 3.0.2 and Technical Specification Surveillance Requirement 3.0.3 are applicable to the VF1P test frequencies, b.s.2.13-Diesel Fuel Oil Testing Program This program implements required testing of both new fuel oil and stored fuel oil. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM standards.

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM D4057 81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, l

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 la accordance with ASTM D975 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.

SAN ON0FRE--UNIT 5.0 20 Amendment No. 4 N,130 I

ATTACHMENT "B" EXISTING TECHNICAL SPECIFICATIONS UNIT 3

i SITS 3.5.1 t

4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Safety injection Tanks (SITS) i 1

LCO 3.5.1 Four SITS shall be OPERABLE.

APPLICABILITY:

MODES I and 2, MODE 3 with pressurizer pressure a 715 psia.

ACTIONS I

CONDITION REQUIRED ACTION COMPLETION TIME 1

A.

One SIT inoperable due A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to boron concentration concentration to not within limits, within limits.-

l B.

One SIT _ inoperable for B.1 Restore SIT to I hour j

reasons other than OPERABLE status.

Condition A.

i 4

j 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-MQ or B not met.

C.2-Reduce pressurira-12 hours-pressure to

< 715 psia, D.

Two or.more SITS D.1 Enter LC0 3.0.3.

Immediately inoperable..

4 e,

- SAN ONOFRE--UNIT 3 3.5-1 Amendment No, 116

l SITS B 3.5.1 BASES ACTIONS

&&1 (continued) during reflood concentrates the boron in the saturated liquid that remains in the core.

In addition, the volume of the SIT is still available for injection.

Since the boron requirements are based on the average boron concentration of the total volume of three SITS, the consequences are less severe than-they would be if an SIT were not available for injection.

Thus, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to return the boron concentration to within limits.

Ikl if one SIT is inoperable, for a reason other than boron concentration, the SIT must be returned to OPERABLE status within I hour.

In this Condition, the required contents of three SITS cannot be assumed to reach the core during a LOCA..Due to the severity of the consequences should a LOCA occur in these conditior.s, the I hour Completion Time to open the valve, remove power to the valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the inoperable accumulator to OPERABLE status.

The Completion Time minimizes the exposure of the plant to a LOCA in these conditions.

C.1 and C.2 If the SIT cannot be restored to OPERABLE-status within the associated Corapletion Time, the plant must 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 < 715 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, te reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

l l

i (continued)

SAN ON0FRE--UNIT 3 B 3.5-7 Amendment No. 116

SITS B 3.5.1 BASES ACTIONS Q.d (continued)

If more than one SIT is inoperable, the unit is in a condition outside the accident analyses.

Therefore, LC0 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each SIT isolation valve is fully open, as indicated in the control room, ensures that SITS are available for injection and ensures timely discovery if a valve should be partially closed.

If an isolation valve is not fully o)en, the rate of injection to the RCS would be reduced.

Altlough a motor operated valve should not change position with power removed, a closed valve could result in not meeting accident analysis assumptions. 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 that ensure the unlikelihood of a misposi' ;oned isolation valve.

s l

SR 3.5.1.2 and SR 3.5 l 1 t

SIT borated water volume and nitrogen cover pressure should I

be verified to be within specified limits every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to ensure adequate injection during a LOCA. Due to the static design of the SITS, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency usually allows the operator sufficient time to identify changes before the limits are reached. Operating experience has shown this Frequency to be appropriate for early detection and correction of off normal trends.

SR 3.5.1.4 Thirty-one days is reasonable for verification to determine that each SIT's boron concentration is within the required limits, because the static aesign of the SITS limits the ways in which the concentration can be changed. The 31 day Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage. A preferred method to sampling is permitted for verifying the boron concentration in the SIT after a greater than or equal (continued)

SAN ONOFRE--UNIT 3 8 3.5-8 Amendment No. 116

__u

SITS B 3.5.1 BASES SURVEILLANCE SR 3.5.1.4 (continued)

REQUIREMENT *,

to 1% volume increase in the SIT not caused by deliberate filling of the SIT from the RWST. This method requires, within six hours, that the new boron concentration of the affected SIT shall be calculated using the volume change of the SIT and the results of the recent RCS boron analysis, if the result of the calculation indicates the boron

- concentration of the affected SIT i; within the lini ts i

specified in this SR, the surveillance verification is satisfied.

It is not necessary to verify boron concentration if the added water is from the RWST, because the water contained in the RWST is within the SIT boron concentration requirements This is consistent with the recommendations of NUREG-1306 (Ref. 5).

SR 3.5.1.5 Verification every 31 days that power is removed from each i

SIT isolation valve operator when the pressurizer pressure is a 715 psia ensures that an active failure en11d not result in the undetected closure of an SIT moto. operated isolation valve.

If this were to occur, only two SITS would be available for injection, given a single failure coincident with a LOCA. Since installation and removal of power to the SIT isolation valve operators is conducted under administrative control, the 31 day Frequency was l

chosen to provide additional assurance that power is removed.

This SR allows power to be supplied to the motor operated isolation valves _ when RCS pressure is < 715 psia, thus allowing operational flexibility by avoiding unnecessary =

delays to manipulate the breakers during unit startups or shutdowns.

Even with power supplied to the valves, inadvertent closure is prevented by the RCS pressure interlock associated with the valves.

Should closure of a i

valve occur in spite of the interlock, the SI signal provided to the valves would open a closed valve in the event of a LOCA.

(continued)

SAN ON0FRE--UNIT 3 B 3.5-9 Amendment No. 116

SITS B 3.5.1 BASES (continued)

REFERENCES 1.

IEEE Standard 279-1971.

2.

UFSAR, Section 6.3.

3.

10 CFR 50.46.

4.

UFSAR, Chapter 15. -

5.

NUREG-1366, December 1992.

SAN ONOFRE--UNIT 3 8 3.5-10 Amendment No. 116 u

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals 5.5.2.12 VentilationFilterTestingProgram(VFTP)

(continued)

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

5.5.2.13_

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

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

The purpose of the program is to establish the following:

a.

At lease once per 92 days and from new fuel oil prior to addition to the storage tanks by verifying that a sample obtained in accordance with ASTM 04057-81 has a water and sediment content of less than or equal to 0.05 volume percent, an API gravity or an absolute specific gravity within limits, and a kinematic viscosity 9 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTH 0975-81.

b.

At least once every 92 days by obtaining a sample of fuel oil in accordance with ASTM D4057-81 and verifying that 1

particulate contamination is less than 10mg/ liter when checked in accordance with ASTM D2276 83, Method A.

l

=w l

SAN ONOFRE-UNIT 3 5.0-20 Amendment No. H4,119

i ATTACHMENT "C" PROPOSED SPEC!flCATIONS UNIT 2

SITS 3.5.1 3.5 EMERGENCYCORECOOLINGSYSTEMS(ECCS) i 3.5.1 SafetyInjectionTanks(SITS)

LCO 3.5.1 Four SITS shall be OPERABLE.

4 APPLICABILITY:

MODES 1 and 2 4

MODE 3 with pressurizer pressure a 715 psia, i

ACTIONS

)

CONDITION REQUIRED ACTION COMPLETION TIME A. -One SIT inoperable due A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to boron concentration concentration to not within limits..

within limits.

Bt ' Ons :SITrinoperable. due B;1' Restore?SITito 72fhours

to' inability to verify

' OPERABLE;statuq

~ '^

)_evel;or; pressure (

B-B C.

One SIT inoperable for C.1 Restore SIT to I h; r 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reasons other than OPERABLE status.

Condition A or B.

G G

i

- D.

Required Action and D.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?

itiQ Bi or B-C not met. ~

G 4

O.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

< 715 psia.

0 0

E.

Two or more SITS E.1 Enter LC0 3.0.3.

Immediately inoperable.

SAN ON0FRE--UNIT 2 3.5-1 Amendment No M 7

1 i

SITS B 3.5.1 BASES ACTIONS L 1 (continued) during reflood concentrates the boron in the saturated liquid that remains in the core, in addition, the volume of the SIT is still available for injection.

Since the boron requirements are based on the average boron concentration of the total volume of three SITS, the consequences are less severe than they would be if an Sl? were not available for injection.

Thus, 72' hours is allowed to return the boron concentration to within limits.

LLI 4f cne S!T i; in;perabic, for : re en -the M hen bcrca eeneentrat4cn,- the SIT ::.unt be retersed-te-CPERASLE :t:tus wMh4n I heu.

In thi: C:nditten, the required contente-ef three4H+-e:nnct bc ::: :cd ic reach the-< ore during ;

LOCA.

Duc 10 the : verity of-the con:cquence; :heeld : LOC 4 eecur in-the:c c;ndM4ener=the I h;ur 0;;plet4en-Tt:0 te open the v:1ve, re::ve power 10 the v he, or re:Lere the proper nier vole c nr nMregen cover pressure en ure: that prc pt :ction wH1 be taken to return the incper:bic eeeuwkter-te-OPERABLE t+tu;.

The-Gempletion Time mi+4mize; the expc;ure ;f the pl:nt t: : LOCA i rthe:c cendM4ensr Section 7;4^of Reference'5l~NUREG 1366,'. discusses surveillance requirementsJin technical specifications for theeinstrument-channels used in the measurement of water ~

leve11and_ pressure,i M ITs.'* ' ' "

Section~7.4LofLReferencei5statesLinlpart:

'The combination'of redundant level and pressure instrumentation for:any single SIT may provide sufficient infctmation 'so-thattit may not be worthwhile to. always ' '

attempt to correct drift associated with one' instrument (with.rehlting radiation. exposures'during entry into containment]71f there were_' sufficient time to_ repair one'in the event that a second one became inoperable.' Because these instruments do not-initiate a safety' action, it is reasonable to extend-the allowable outage for them. The (NRC) staff, therefore,N recommends that an additienal t

(continued)

SAN ON0FRE--UNIT 2 B 3.5-7 Amendment No, M7

SITS B 3.5.1 e

BASES ACTIONS fL1 (continued) ccndition'be estab*,ished for the' specific case, where 'One water level a[$1T)71s inoperable due'to the inoperability of accumulator nd pressure channels," in-which the completion time to= restore the accumulator-tol operable status Will be '

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; 'A Configuration Risk Management-Program defined in Administrative Controlsc section15.5.2el4(CRMP) is ~

implemented?in the event of. Condition 8.- While technically inoperable, the accumulator would.beiavailable to fulfill its safety. function during;this time and thus, this_ change would have a' negligible" increase;in-risk,."

101 If'one SIT ~is inoperable 'for:a reason:other than boron concentration or the inability to. verify level or pressure, the SIT must beireturned to OPERABLE status within 24' hours.

In this Condition the: required contents of three SITS' cannot be assumed,to reach the core.during a LOCA as is assumed in Appendix K to:100FR50.'

ReferenceTprovid6s series of deterministic 'and probabilistic findinas that support 424 hours0.00491 days <br />0.118 hours <br />7.010582e-4 weeks <br />1.61332e-4 months <br /> as being either " risk beneficial" or " risk neutral" in-comparison'to shorter periods for restoring the SIT to OPERABLE status.

Reference.7 discusses a best-estimate analysis that confirmed that,d by either operation of one Low'Pressuredurinc large-break t can be prevente SafetyLinjection (LPSIE pump or-the operation of-or.e-High Pressure Safety injectnon:-(HPSI)' pump and a singlo SIT.

Reference 7 also discusses a plant-specific Drobabilistic analysis that'evaluatedstne risk-impact of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ~ ~

recovery period;in cotparison to shorter recovery period Q A Configure. tion' Risk' Management: Program Administrative.Controlssection5.5.2.14(CRMP)"dednedin is' implemented in the event'of.. Condition C.

C0.1 and GD.2 If the SIT cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to < 715 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 requiredplantconditionsfromfullpower,conditionsinan orderly manner and without challenging plant systems.

=

(continued)

SAN ON0FRE--UNIT 2 B 3.5-8 Amendment No. -lW L

l

~

SITS B 3.5.1 BASES ACTIONS (L1 (continued)

If more than one SIT is inoperable, the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEllLANCE SR 3.5.1.1 REQUIPEMENTS Verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each SIT isolation va've is fully open, as indicated in the control room, ensures that SITS are available for injection and ensures timely discovery if a valve should be partially closed.

If an isolation valve is not fully o)en, the rate of injection to the RCS would be reduced. Altlough a motor operated valve should not change position with power removed, a closed valve could result in not meeting accident analysis assumptions. 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 that ensure the unlikelihood of a mispositioned isoletion valve.

l SR 3.5.1.2 and SR 3.5.1.3 SIT borated water volume and nitrogen cover pressure should be verified to be within specified limits every-12 hours in order to ensure adequate injection during a LOCA.

Due to the static design of the SITS, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency usually allows the-operator sufficient time to identify-changes before the limits are reached. Operating experience has shown this frequency to be appropriate for early detection and correction of off normal trends.

SR 3.5.1.4 Thirty-one days is reasonable for verification to determine that each SIT's boron concentration is within the required limits, because the static design of the SITS limits the ways in which the concentration can be changed.

The 31 day Frequency is adeq'Jate to identify changes that could occur from mechanisms such as stratification or inleakage. A 3 referred method to sampling is permitted for verifying the

)oron concentration in the SIT after a greater than or equal (continued)

SAN ON0FRE--UNIT 2 B 3.5-9 Amendment No. 4W

SITS B 3.5.1 BASES 4

SURVEILLANCE SR 3.5.1.4 (continued)

REQUIREMENTS to 1% volume increase in the SIT not caused by deliberate filling of the SIT from the RW5T. This method requires, within six hours, that the new toron concentration of the affected SIT shall be calculated using the volurre change of the SIT and the results of the recent RCS boron analysis.

If the result of the calculstion indicates the boron concentration of the affected SIT is within the limits i

specified in this SR, the surveillance verification is satisfied.

It is not necessary to verify boron concentration if the added water is from the RWST, because the water contained in the RWST is within the SIT boron concentration requirements.

This is consistent with the recommendations of NUREG-1366 (Ref. 5)? Reference 16[and Reference 17{

~

~

SR 3.5.1.5 Verification every 31 days that power is removed -from each SlT isolation valve operator when the pressurizer pressure is a 715 psia ensures that an active failure could not-result in the undetected closure of an SIT motor operated isolation valve.

if this were to occur, only two SITS would be available for injection, given a single failure coincident with a LOCA.

Since installation and removal of power to the SIT isolation valve operators is conducted 4

under administrative control, the 31 day Frequency was chosen to provide additional assurance.that power is removed.

This SR allows power to be supplied to the motor operated isolation valves when RCS pressure is < 715 psia, thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during unit startups or-shutdowns.

Even with power supplied to the valves,

. inadvertent closure is prevented by the RCS pressure interlock associated with the valves.

Should closure of a valve occur in spite of the interlock, the SI signal provided to the valves would open a closed valve in the event of-a LOCA.

1 (continued)

SAN ON0FRE--UNIT 2 B 3.5-10 Amendment No. 4W

i l

l SITS B 3.5.1 BASES (continued) i REFERENCES 1.

IEEE Standard 279 1971.

2.

UFSAR, Section 6.3.

3.

10 CFR 50.46.

4.

UFSAR, Chapter 15.

5.

NUREG 1366, December 1992.

6F"iNRC~ Generic Letter 93205,7"Line; Item? Technical

' ~ ~ '

Specification-Improvementsito: Reduce Surveillance Requirements-for Testin 27,; 1993.^ ""g. During, PowerL 0perat ions, "

September

" ' ' ~

7;

' CE NPSD-994 ~"CE0G'Coint:' Application' Report'for' Safety

" ~ InjectionlantA0T/STI LExten; don,I Aprilil995.,

'O SAN ON0FRE--UNIT 2-B13.5'10a Amendment No. W

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

(continued)

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

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 stan:!ards.

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 accord 2nce 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 D975 81.

b.

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

SK 234C Confj guration~ Ri ski Management l Program} (CRMP)

The Configuration'Ris,,

?qementProgram^(CRMP):providesa procedura11 red risk info,P

'ssessment,to manage-the: risk associatedwithequipmentLinoperability.- The prsgram. applies'to technical: specification structures, systems,: or components for which a risk informe(Completion 1Timelhas been granted RThe, orogram-shall

~~~ ~

~

include,the following elements:

al Pr6 visions' for the control andTimplementationlof a Leve1 ~1: at power internal events PRA informed methodology.- The b1#

assessment shall be capable of; evaluating.the applicable plant configurations b;:

Provisions for performing-an~ assessment" prior to entering the LCO Condition-for preplanned activities, c"..

Provisions' for~ performing'an assessment ^after entering the LC0 Condition for unplanned entry jnto the LCO Condition.

1 SAN ON0FRE--UNIT 2 5.0-20 Amendment No. 127,130

- -..~_.

Procedures, Progre ns, and Manuals 5.S

)

i 5.5 Procedures, Programs, and Manuals 5.5.2.14'

' Configuration. Risk'ManagementProgram;(CRMP);(Conti_nued) i d;E~ the discovery of additional equipment outf of' service' Provisions

~~

conditions while=in the,LCO Condition.

g

,t

~TProvisions'for considering"othtr7 appl.icable ' risk ^significant e.,

contributors such 'as Level 2 issues, and.'. external eventsi qualitativelyor. quanti (atively;'"

s l

l l

l l

l l

l.

i SAN ONOFRE--UNIT 2 5.0-20a Amendment No. +Nrl40

o ATTACHMENT "0" PROPOSED SPECIFICATIONS UNIT 3 l

SITS 3.5.1 3.5 EMERGENCYCORECOOLINGSYSTEMS(ECCS)

-3.5.1 Safety injection Tanks (SITS)

LCO 3.5.1 four SITS shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2 MODE 3 with pressurizer pressure a 715 psia.

i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One SIT inoperable due A.1 Restort f.oron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to boron concentration concenttation to not within limits, within limits.

B[10ne'$1T inoperable'due B;1# " Restore ~ SIT to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to inability to: verify

~'

' OPERABLE status!

level:or; pressure. "

~

~ "

~

B B

C.

One SIT inoperable for C.1 Restore SIT to I h = 24; hours reasons other than OPLRABLE status.

~ ~

Condition A or B.

G G

D..

Required Action and D.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 Ai MD B;' or B-C not met. "

G D.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

< 715 psia.

-0 0

E.

Two or more SITS E.1 Enter LC0 3.0.3.

Intnediately inoperable.

SAN ON0FRE--UNIT 3 3.5-1 Amendment No. H6 l

l

SITS B 3.5.1 BASES ACTIONS M (continued) during reflood concentrates the boron in the saturated liquid that remains in the core.

In addition, the volume of the SIT is still available for injection.

Since the boron requirements are based on the average boron concentration of the total volume of three SITS, the consequences are less severe than they would be if an SIT were not available for injection.

Thus, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to return the boron concentration to within limits, i

M 4f One S!T i: incper bler-for reasen-ether than beren eeneentration,--th: S!T mu;t be returned te OPEP2BLE :tet-us Mth k I hour.

In th4+-Gendition, the required 00ntent: Of three SI-T+-cennet be Oc;umed to reach the :Or during t0CA.

Due to th: ;; verity Of th: con;;quence: :hould : LOCA Occur in these-eend44Acn:, the I hour 00mplet40n T :: to open-the valve,- re=0ve p0wer-t+ th: talve, Or re:ter the proper water vele= Or-nitregen ecver pres;ure en ure; that prc pt :: tion will be t ken to return the inoper:bic eeeumul*ter t0 OPEP3BLE : tete:.

The 00 ple ien-T4me mM4M::: th: exp0 ure of the plant-to : LOCA in the::

condition:r Section17;4 of Reference 5f NUREG-1366 Fdiscusses surveillanceirequirements in: technical specifications for the dnstrument channels used intthe measurement of water' level and pressure lin SITS. ~ ~

~

Section$4Lof; Reference 5'statesiin:part:

fThe combination of: redundant level and pressure instrumentat-ion;for:any single SIT may provide sufficient informatiorksa that. it may not be worthwhile' to;always attempt to correct drift associated with oneLinstrument

[with resulting radiation exposures during~ entry into containment) ifsthere were sufficient time to repair,one in the event that a second one-became; inoperable.

Because these' instruments do not initiate a-safety' action, it.is reasonable-to extend the allowable outage, for; them'. -The (NRC] staff,. therefore,; recommends: that an; additional (continued)

SAN ON0FRE--UNIT 3 B 3.5-7 Amendment No. 446

4 s* -

SITS B 3.5.1 BASES ACTIONS 161 (contint:ed) conditionibe~ established 7for thelspecific~ case waterilevella[ SIT]:isiinoperable due'toithe inop, Mere "One accumulator >

erability.of nd pressure channels," fin which the completion-time to: restore the' accumulator to ' operable status will be~

7?shours. JA Configuration--Risk, Management; Program CP.MP d (ined31n' Administrative Controls section 5.5.2J4'is ~)'

i.aplemhnted in the; event of-Condition.BM WhileA.se nic~all g,e1 inoperable; the, accumulator would-be available to' fulfill'y its-safety function durin thus guld;haveLa'negligibleli_githis: time?and/"y "h~this " hang"e ncreagejin;riskj

~"

fHkl If"one: SIT 11s! inoperable? for^a" reason.

.nen' boron concentration or theninability + % verifyi.evelior, pressure l the. SIT must;be returned to OPE

.E status;within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.T In this Condition the< requirc,.ontents:ofcthree1 SITS ~ --"

cannotb# assumed $'toreachtheAareduring^laLOCAfas1.5 3

assumed in Appendi,x L toj 0C(R50;~ - ~

'~

l Reference?7'provides7seriesTof'determinitticTand l

probabilistic findings: that:supporti24 ehours Las: beino eitherc" risk beneficial"? or>"rlsk-neutral" sin: comparison ~ to -

shorter;periodsifer restoring the-SITJto: OPERABLE status Reference 7 discussesia best-estimate 1 analysis:that" ~ ~ y l

conf 1 reed;that,"during 1arge-break LOCA;scenariose corelmelt can^be-prevented b SafetyiInjection:(y either. operation'oftone Low??ressure ~

LPSINpump or theLoperatton'ofaone Hi Reference 7.ab o; discusses?(HPSI)tpump,and a-sinale SIT.gh Pressure ~ Safe +y :In1ection c

a plant-specific zoro5abilistic analysi's' thatTevaluted the risk-impact = of the r24 hour recovemperiodiin;comparisontoshorterfrecoveryjperiodsi A'Configurati on' Ri sK" Management' ProgramT' Adminissative Controls section A5.2.','MP)~ defined'in

, imp ~lemented : in' g"O1 the event oRCondj} ion 0;L -" ~

^

^

~

G0.1 and GD.2 If the SIT cannot be '-ewored to OPERABLE status within the associated Completior. Time, the plant must be brought to a MODE in which ti,a LCO does not apply.

Tu 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 < 715 psia within I? hours.

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

(continued)

%N ONOFRE--UNIT 3 B 3.5-8 Amendment No. -146

]

l l

a

-m 1

SITS B 3.5.1 l

BASES

.~

ACTIONS IL1 l

(continued)

If more than om SIT is inoperable, the unit is in a condition outsid) the accident analyses. Therefore, LC0 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that each SIT isolation valve is fally open, as indicated in the control room, ensures that SITS are available for injection and ensur~ timely discovery if a valve should be partiall3

ed.

If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a 10 tor operated valve should not change position with power removed, a closed valte could result in not meeting acciJent analysis assumptions. 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 that ensure the unlikelihood of a mispositioned isolation valve.

SR 3.5.1.2 and SR 3.5.1.3 SIT borated water volume and nitrogen cover pressure should be verified to be within specified limits every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in order to ensure adequatt injection during a LOCA, Due to the static desigr of the SITS, a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Fiequency usually allows the operator sufficient time to identify changes before the limits aie reached. Operating experience has shown this Frequency to be appropriate for early detection ano correction of off normal trends.

SR 3.5.1.4 Thirty-one days is reasonable for verification to determine that each SIT's boron concer.tration is within the required limits, because the static design of the SITS limits the ways in which the concentration can be changed.

The 31 day frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage. A preferred method to sampling is permitted for verifying the baron concentration in the SIT after a greater than or equal (continued)

SAN ONOFRE--UNIT 3 2 3.5-9 Amendment No. 446 a

SITS B 3.5.1 BASES

]

SURVEILLANCE SR 3.5.1.4 (continued)

REQUIREMENTS to 1% volume increase in the SIT not caused by deliberate filling of the SIT from the RWST.

This method requires, within six hours, that the new boron concentration of the affected SIT shall be calculated using the volume change of the SIT and the results of the recent RCS boron analysis.

If-the result of the calculation indicates the boron concentration of the affected-SIT is within the limits specified in this SR, the surveillance verification is satisfied.

It is not necessary to verify boron concentration if the added water is from the RWST, because the water contained ir, the RWST is within the SIT boron concentration requirements.

This is consistent with the recommendations of NUREG-1366 (Ref. 5)C' Reference ~6 ?and Refere..ncej7)

~

~ ~ ~ ~ ~ ~

SR 3.5.1.5 Verification every 31 days that power is removed from each SIT isolation valve operator when the pressurizer pressure.

is a 715 psia ensures that an active failure could not result in the undetected closure of an SIT motor operated isolat 'on valve.

If this were to occur, only two SITS would be available for injection, given a single failure coincident with a LOCA.

Sir..a instal'.ation and removcl of power to the SIT isolation valve operators is conducted under administrative centrol, the 31 day Frequency was

?

chosen to provide addit'. anal assurance that power is removed.

7 1

This SR allows power to be supplied to the motor operated isolation valves when RCS pressure is < 715 psia, thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during unit startups or shutdowns.

Even with power supplied to the v Ives, inadverter:t closure is prevented by the US pressure interlock associated with the valves.

Shoald closure of a valve occur.in spite of the interlock, the SI signal provided to the valves would open a closed valve in the event of a LnCA.

c (continued)

SAN 000FRE--UNIT 3 8 3.5-10 Amendment No. 4 M

SITS B 3. 5.1-BASES (continued)

REFERENCES 1.

IEEE Standard 279-1971.

2.

UFSAR, Section 6.3.

3.

10 CFR 50.46.

4.

UFSAR, Chapter 15.

5.

NUREG-1366, December 1992.

6k r NRLf Generif Letter:93?05F"Line:ItereTechnital

"" Specification ImprovementsIto Reduce Surveillance Requirements 1for-sTesting~During~PowerOp'erationsg September 27,31993(

~' ~" '

~ ^ " ~

~ ~ ^ ~ "

71-f CE NPSD;994',9CEOG7Doint" Application'ReportJfoMSafety

~~'~ ' _Injecti_onj TanyJOT/jTI Ex, tension,"; Apri,1 f 1995f'~' ~~

SAN ON0FRE--UNIT 3 B 3'.5-10a Amendment No. 446 r

J

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

(continued)

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

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

The purpose of the program is tu establish the following:

a.

Ai laast once per 92 days and from new fuel oil prior to addit,on to the storage tanks by verifying that a sample obtained in accordance with ASTM-D4057-81 has a water and sediment cont. 't of less than or equal to 0.05 volume percent, an API gravis,.

. an aosolute specific gravity within limits, and a kinematic viscosity 0 40 C of greater than or equal to 1.9 but less than or equal to 4.1 when tested in accordance with ASTM-0975-81.

b.

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

5.5.2;141 Configuration. Risk' Management ~ Program l(CRMP)

Thel Configuration' Ri'sk:ManagementLProgamT(CRMP)? pro.vides~ 'a procbduralized risk-informed assessment to manage the risk' hssociated with equipment.inoperability. The: program applies to technical specification structures, s'ystems, _or ~ components forL which

a. risk-informed Completion Time has been granted. The_ program shall include the following elements:,

Provisions for' the control andimplementationf of a Level 1 at b"if l a.

power internal events PRA-informed methodalogy.

The assessment shall'be~ capable.of evaluating the applicable ~ plant configuration.

~'

b.

Provisions'for~performirg an' assessment prior to~ entering the LCO Condition for preplanned activities.

Provisions for p?rforming 'an assessment"after entering the LC0 c.

Condition for unplanned entry into the LCO Condition.

I SAN ON0FRE--UNIT 3 5.0-20 Amendment No. 116,119

s, r

3..-

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals

!@dil4);m; J Configurat i KRi s k(Managpntl Program} (CRMP)jd (Cont j nued) db"3 Provisions':foFasses~ sing #the"need i forf add i ti onal 'ac t i onil ifter y,

--ofiadditional'equipmentLout ofiservide"~ ~~~"

c. ond_itions^whi.leli.n the_iLCO~LCond,itions ~

~ ~ ~ ~ ~

~, _ - -

gg,4 e_F T.ProvisionsWorTconsidegrin". otheFapplicabWrisk7 sign'ific_an_t g,

pali _tative]yj oiqua_ntjtatiyelyp ~~ ~

~ ~ ~ ~ ~ ' ^ ' ~

SAN ON0FRE--UNIT 3 5.0l-20a Amendment No. 116,119

.