~~~~.WI fDr 50"N' Douglas R. Bauder 

Site Vice President & Station Manager 

San Onofre Nuclear Generating Station 

An EDISON INTERNATIONAL® Company 

U. S. Nuclear Regulatory Commission 

ATTN: Document Control Desk 

Washington, D.C. 20555 

Subject: Docket No. 50-361 

Apr; 1 9, 2013 

Supplement 1 to Amendment Application Number 263 

Steam Generator Program 

San Onofre Nuclear Generating Station, Unit 2 

10 CFR 50.90 

Reference: Letter from Mr. Peter T. Dietrich (SCE) to NRC dated April 5, 2013, 

Docket No. 50-361, Amendment Application Number 263 

Steam Generator Program, San Onofre Nuclear Generating Station, 

Unit 2 

Dear Sir or Madam: 

Southern California Edison (SCE) submitted Amendment Application No. 263 to Docket 

No. 50-361 (Reference). The Enclosure provides supplemental information on the 

Technical Specification impact assessment for SONGS Unit 2 operation at 70% Rated 

Thermal Power in support of the referenced Amendment Application. This supplement 

does not change the conclusions reached in the No Significant Hazards Consideration 

section of the Amendment Application and therefore, the No Significant Hazards 

Consideration is still applicable. 

Should you have any questions, or require additional information, please contact 

Mr. Mark Morgan, Licensing Lead, at (949) 368-6745. 

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

Executed on 4/q/~/3 (Date) 

P.O. Box 128 

San Clemente, CA 92672 

(949) 368-9275 PAX 89275 

Fax: (949) 368-9881 

Doug.Bauder@sce.com 

Sincerely, 
Document Control Desk -2- April 9, 2013 

Enclosure: Technical Specification Impact Assessment for SONGS Unit 2 Operation at 

70% Power 

cc: A. T. Howell III, Regional Administrator, NRC Region IV 

R. Hall, NRC Project Manager, SONGS Units 2 and 3 

B. Benney, NRC Project Manager, SONGS Units 2 and 3 

G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 

S. Y. Hsu, California Department of Public Health, Radiologic Health Branch 
ENCLOSURE 

Technical Specification Impact Assessment for 

SONGS Unit 2 Operation at 70% Power 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

NOTES: 

(1) Power dependency is defined as the Technical Specification LCO, Applicability, Action 

Statement, or Surveillance Requirement containing a reference to a specific power level or a 

requirement that is power dependent. References solely to MODE 1 or MODE 2 are not 

considered power dependent. 

1.1 DEFINITION Power level dependent. Definitions for Rated No 

Thermal Power and Modes (Table 1.1 -1) are not 

affected by reduced power operation. 

1.2 LOGICAL Not power level dependent. No 

CONNECTORS 

1.3 COMPLETION TIME Not power level dependent. No 

1.4 FREQUENCY Not power level dependent. No 

2.0 SAFETY LIMITS Not power level dependent. No 

3.0 LCO AND SR Not power level dependent. No 

APPLICABILITY 

3.1 .1 SHUTDOWN MARGIN Not power level dependent; applicable only to No 

(SDM) - TAVG > 200 Modes 3 and 4. 

DEGF 

3.1.2 SHUTDOWN MARGIN Not power level dependent; applicable only to Mode No 

(SDM) - T AVG s; 200 5. 

DEGF 

3.1 .3 REACTIVITY BALANCE Not power level dependent. Surveillance No 

Requirement is addressed in RAI 11 (Table 2). 

3.1.4 MODERATOR Power level dependent. MTC limits are analyzed as No 

TEMPERATURE part of the reload analyses. Operation at 70% 

COEFFICIENT (MTC) power does not impact the LCO, Applicability, or 

Actions. Surveillance Requirements are addressed 

in RAI 11 (Table 2). 

3.1 .5 CONTROL ELEMENT Power level dependent. The CEA alignment LCO No 

ASSEMBL Y (CEA) and Surveillance Requirements are independent of 

ALIGNMENT power. Required actions as per the COLR are to 

reduce power after CEA deviation for initial power 

greater than 50% power. Operation at 70% power 

does not impact required actions. 

3.1.6 SHUTDOWN CONTROL Not power level dependent. The shutdown CEAs No 

ELEMENT ASSEMBL Y are withdrawn from the core at power. No 

(CEA) INSERTION distinction is made between power levels in Mode 1. 

LIMITS 

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TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.1.7 REGULATING CEA Power level dependent. The LCO is dependent on No 

INSERTION LIMITS power because the CEA insertion COLR 

requirements are power dependent. The CEA 

insertion limit Surveillance Requirements remain 

valid for operation at 70% power. Power dependent 

insertion limits (POlL) are validated in reload 

analysis. 

3.1.8 PART LENGTH Power level dependent. The LCO is dependent on No 

CONTROL ELEMENT power because the part length CEA insertion COLR 

ASSEMBL Y (CEA) requirements are power dependent. The part length 

INSERTION LIMITS CEA insertion limit Surveillance Requirements 

remain valid for operation at 70% power. Power 

dependent insertion limits (POlL) are validated in 

reload analysis. 

3.1.9 BORATION SYSTEMS - Not power level dependent; requirements are the No 

OPERATING same for all power levels. 

3.1.10 BORATION SYSTEMS - Not power level dependent; applicable only to No 

SHUTDOWN Modes 5 and 6. 

3.1.11 Not Used N/A No 

3.1.12 SPECIAL TEST Not power level dependent; applicable only to No 

EXCEPTION - LOW Modes 2 and 3. 

POWER PHYSICS 

TESTING 

3.1.13 SPECIAL TEST Power level dependent. The listed LCOs may be No 

EXCEPTION - AT suspended provided thermal power is < 85% and 

POWER PHYSICS linear heat rate does not exceed the limit in the 

TESTING COLR. Operation at 70% power does not impact 

the LCO, Applicability, Actions or Surveillance 

Requirements. 

3.1.14 SPECIAL TEST Power level dependent. The listed LCOs may be No 

EXCEPTION - suspended provided certain CEA criteria, and LHR 

REACTIVITY and DNBR do not exceed COLR limits. Operation at 

COEFFICIENT 70% power does not impact compliance with this 

TESTING specification. 

3.2.1 LINEAR HEAT RATE Power level dependent. LHR limit is validated in No 

(LHR) reload analysis. Operation at 70% power does not 

impact compliance with this specification. 

3.2.2 PLANAR RADIAL Power level dependent. Operation at 70% power No 

PEAKING FACTORS does not impact the LCO, Applicability, or Actions. 

(Fxy) Surveillance Requirement is addressed in RAI 11 

(Table 2). 

3.2.3 AZIMUTHAL POWER Power level dependent. Operation at 70% power No 

TILT (Tq) does not impact the LCO, Applicability, Actions or 

Surveillance Requirements. Surveillance 

Requirement 3.2.3.3 is addressed in RAI 11 

(Table 2). 

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TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.2.4 DEPARTURE FROM Power level dependent. Four methods are specified No 

NUCLEATE BOILING for maintaining DNBR. A power dependency is 

RATIO (DNBR) specified in the COLR. Operation at 70% power 

does not impact the LCO, Applicability, Actions or 

Surveillance Requirements. Operation at 70% 

power does not change the requirements of the 

COLR. 

3.2.5 AXIAL SHAPE INDEX Power level dependent. Operation at 70% power No 

(ASI) does not impact the LCO, Applicability, Actions or 

Surveillance Requirements. Operation at 70% 

power does not change the requirements of the 

COLR. 

3.3.1 REACTOR Power level dependent. RPS trip setpoints are No 

PROTECTIVE SYSTEM validated in reload analysis. Operation at 70% 

(RPS) power does not impact the LCO, Applicability, 

INSTRUMENTATION - Actions or Surveillance Requirements. Surveillance 

OPERATING Requirements 3.3.1 .2, 3.3.1.5 and 3.3.1.11 are 

addressed in RAI 11 (Table 2). 

3.3.2 REACTOR Not power level dependent; applicable only to No 

PROTECTIVE SYSTEM Modes 3, 4 and 5. 

(RPS) 

INSTRUMENTATION -

SHUTDOWN 

3.3.3 CONTROL ELEMENT Not power level dependent; requirements are the No 

ASSEMBLY same for all power levels. 

CALCULATORS 

3.3.4 REACTOR Not power level dependent; requirements are the No 

PROTECTIVE SYSTEM same for all power levels. 

(RPS) LOGIC AND TRIP 

INITIAION 

3.3.5 ENGINEERED SAFETY Not power level dependent; requirements are the No 

FEATURES same for all power levels. 

ACTUATION SYSTEM 

(ESFAS) 

INSTRUMENTATION 

3.3.6 ENGINEERED SAFETY Not power level dependent; requirements are the No 

FEATURES same for all power levels. 

ACTUATION SYSTEM 

(ESFAS) LOGIC AND 

MANUAL TRIP 

3.3.7 DIESEL GENERATOR Not power level dependent; requirements are the No 

(DG) - same for all power levels. 

UNDERVOLTAGE 

START 

3.3.8 CONTAINMENT Not power level dependent; requirements are the No 

PURGE ISOLATION same for all power levels. 

SIGNAL (CPIS) 

3 of 8 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.3.9 CONTROL ROOM Not power level dependent; requirements are the No 

ISOLATION SIGNAL same for all power levels. 

(CRIS) 

3.3.10 Not Used NIA No 

3.3.11 POST ACCIDENT Not power level dependent; requirements are the No 

MONITORING (PAM) same for all power levels. 

INSTRUMENTATION 

3.3.12 REMOTE SHUTDOWN Not power level dependent; requirements are the No 

SYSTEM same for all power levels. 

3.3.13 SOURCE RANGE Not power level dependent; applicable only to No 

MONITORING Modes 3, 4 and 5. 

CHANNELS 

3.4.1 RCS DNB PRESSURE, Power level dependent. Power dependency is as No 

TEMPERATURE AND specified in the COLR. RCS operating limits are 

FLOW LIMITS analyzed as part of the reload analyses. RCS flow 

limit is addressed in RAI 12. Operation at 70% 

power does not impact the LCO, Applicability, 

Actions or Surveillance Requirements. Operation at 

70% power does not change the requirements of 

the COLR. 

3.4.2 RCS MINIMUM Power level dependent. Operation at 70% power No 

TEMPERATURE FOR does not impact the LCO, Applicability, Actions or 

CRITICALITY Surveillance Requirements. 

3.4.3 RCS PRESSURE AND Not power level dependent; requirements are the No 

TEMPERATURE (PIT) same for all power levels. 

LIMITS 

3.4.3.1 PRESSURIZER Not power level dependent; requirements are the No 

HEATUPAND same for all power levels. 

COOLDOWN LIMITS 

3.4.4 RCS LOOPS - MODES Not power level dependent; requirements are the No 

1 AND 2 same for all power levels. 

3.4.5 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 

3 3. 

3.4.6 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 

4 4. 

3.4.7 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 

5, LOOPS FILLED 5. 

3.4.8 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 

5, LOOPS NOT FILLED 5. 

3.4.9 PRESSURIZER Not power level dependent; requirements are the No 

same for all power levels. 

3.4.10 PRESSURIZER Not power level dependent; requirements are the No 

SAFETY VALVES same for all power levels. 

3.4.11 Not used NIA No 

4 of 8 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.4.12.1 LOW TEMPERATURE Not power level dependent; applicable only to No 

OVERPRESSURE Modes 4, 5, and 6. 

PROTECTION (L TOP) 

SYSTEM RCS 

TEMPERATURE <= 

PTLR LIMIT 

3.4.12.2 LOW TEMPERATURE Not power level dependent; applicable only to Mode No 

OVERPRESSURE 4. 

PROTECTION (L TOP) 

SYSTEM RCS 

TEMPERATURE> 

PTLR LIMIT 

3.4.13 RCS OPERATIONAL Not power level dependent; requirements are the No 

LEAKAGE same for all power levels. 

3.4.14 RCS PRESSURE Not power level dependent; requirements are the No 

ISOLATION VALVE same for all power levels. 

(PIV) LEAKAGE 

3.4.15 RCS LEAKAGE Not power level dependent; requirements are the No 

DETECTION same for all power levels. 

INSTRUMENTATION 

3.4.16 RCS SPECIFIC Power level dependent. Action A.1 and Figure No 

ACTIVITY 3.4.16-1 are addressed in RAI 11 . Operation at 

70% power does not impact the LCO, Applicability, 

remaining Actions, or Surveillance Requirements. 

3.4.17 STEAM GENERATOR Not power level dependent; requirements are the No 

(SG) TUBE INTEGRITY same for all power levels. 

3.5.1 SAFETY INJECTION Not power level dependent; requirements are the No 

TANKS (SITs) same for all power levels. 

3.5.2 ECCS - OPERATING Not power level dependent; requirements are the No 

same for all power levels. 

3.5.3 ECCS - SHUTDOWN Not power level dependent; applicable only to No 

Modes 3 and 4. 

3.5.4 REFUELING WATER Not power level dependent; requirements are the No 

TANK (RWT) same for all power levels. 

3.5.5 TRISODIUM Not power level dependent; requirements are the No 

PHOSPHATE (TSP) same for all power levels. 

3.6.1 CONTAINMENT Not power level dependent; requirements are the No 

same for all power levels. 

3.6.2 CONTAINMENT AIR Not power level dependent; requirements are the No 

LOCKS same for all power levels. 

3.6.3 CONTAINMENT Not power level dependent; requirements are the No 

ISOLATION VALVES same for all power levels. 

3.6.4 CONTAINMENT Not power level dependent; requirements are the No 

PRESSURE same for all power levels. 

5 of 8 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.6.5 CONTAINMENT AIR Not power level dependent; requirements are the No 

TEMPERATURE same for all power levels. 

3.6.6.1 CONTAINMENT SPRAY Not power level dependent; requirements are the No 

AND COOLING same for all power levels. 

SYSTEMS 

3.6.6.2 CONTAINMENT Not power level dependent; applicable only to Mode No 

COOLING SYSTEM 4. 

3.6.7 Not Used N/A No 

3.6.8 CONTAINMENT DOME Not power level dependent; requirements are the No 

AIR CIRCULATORS same for all power levels. 

3.7.1 MAIN STEAM SAFETY Power level dependent. Table 3.7.1-1 is validated No 

VALVES (MSSVs) as part of the reload analyses. Operation at 70% 

power does not impact the LCO, Applicability, 

Actions, or Surveillance Requirements. 

3.7.2 MAIN STEAM Not power level dependent; requirements are the No 

ISOLATION VALVES same for all power levels. 

(MSIVs) 

3.7.3 MAIN FEEDWATER Not power level dependent; requirements are the No 

ISOLATION VALVES same for all power levels. 

(MFIVs) 

3.7.4 ATMOSPHERIC DUMP Not power level dependent; requirements are the No 

VALVES (ADVs) same for all power levels. 

3.7.5 AUXILIARY Not power level dependent; requirements are the No 

FEEDWATER (AFW) same for all power levels. 

SYSTEM 

3.7.6 CONDENSATE Not power level dependent; requirements are the No 

STORAGE TANK (CST) same for all power levels. 

3.7.7 COMPONENT Not power level dependent; requirements are the No 

COOLING WATER same for all power levels. 

(CCW) SYSTEM 

3.7.7.1 COMPONENT Not power level dependent; requirements are the No 

COOLING WATER same for all power levels. 

(CCW) SAFETY 

RELATED MAKEUP 

SYSTEM 

3.7.8 SALTWATER COOLING Not power level dependent; requirements are the No 

SYSTEM (SWC) same for all power levels. 

3.7.9 Not Used N/A No 

3.7.10 EMERGENCY CHILLED Not power level dependent; requirements are the No 

WATER (ECW) same for all power levels. 

3.7.11 CONTROL ROOM Not power level dependent; requirements are the No 

EMERGENCY AIR same for all power levels. 

CLEANUP SYSTEM 

(CREACS) 

6 of 8 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.7.12 - 3.7.15 Not Used N/A No 

3.7.16 FUEL STORAGE POOL Not power level dependent. No 

WATER LEVEL 

3.7.17 FUEL STORAGE POOL Not power level dependent. No 

BORON 

CONCENTRATION 

3.7.18 SPENT FUEL Not power level dependent. No 

ASSEMBL Y STORAGE 

3.7.19 SECONDARY Not power level dependent; requirements are the No 

SPECIFIC ACTIVITY same for all power levels. 

3.8.1 AC SOURCES- Not power level dependent; requirements are the No 

OPERATING same for all power levels. 

3.8.2 AC SOURCES- Not power level dependent. No 

SHUTDOWN 

3.8.3 DIESEL FUEL OIL, Not power level dependent; requirements are the No 

LUBE OIL, AND same for all power levels. 

STARTING AIR 

3.8.4 DC SOURCES- Not power level dependent; requirements are the No 

OPERATING same for all power levels. 

3.8.5 DC SOURCES- Not power level dependent. No 

SHUTDOWN 

3.8.6 BATTERY Not power level dependent; requirements are the No 

PARAMETERS same for all power levels. 

3.8.7 INVERTERS - Not power level dependent; requirements are the No 

OPERATING same for all power levels. 

3.8.8 INVERTERS - Not power level dependent. No 

SHUTDOWN 

3.8.9 DISTRIBUTION Not power level dependent; requirements are the No 

SYSTEMS - same for all power levels. 

OPERATING 

3.8.10 DISTRIBUTION Not power level dependent. No 

SYSTEMS -

SHUTDOWN 

3.9.1 BORON Not power level dependent; applicable only to Mode No 

CONCENTRATION 6. 

3.9.2 NUCLEAR Not power level dependent; applicable only to Mode No 

INSTRUMENTATION 6. 

3.9.3 CONTAINMENT Not power level dependent. No 

PENETRATIONS 

3.9.4 SHUTDOWN COOLING Not power level dependent; applicable only to Mode No 

(SDC) AND COOLANT 6. 

CIRCULATION - HIGH 

WATER LEVEL 

7 of 8 
TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER 

SONGS Unit 2 Description TS LCO, Applicability, Actions, & TS Change 

Tech. Spec. Surveillance Requirements Impact Required? 

3.9.5 SHUTDOWN COOLING Not power level dependent; applicable only to Mode No 

(SDC) AND COOLANT 6. 

CIRCULATION - LOW 

WATER LEVEL 

3.9.6 REFUELING WATER Not power level dependent. No 

LEVEL 

4.1 DESIGN FEATURES -- Not power level dependent. No 

SITE 

4.2 REACTOR CORE Not power level dependent. No 

4.3 FUEL STORAGE Not power level dependent. No 

5.1 RESPONSIBILITY Not power level dependent. No 

5.2 ORGANIZATION Not power level dependent. No 

5.3 UNIT STAFF Not power level dependent. No 

QUALIFICATION 

5.4 TECHNICAL Not power level dependent. No 

SPECIFICATION (TS) 

BASES CONTROL 

5.5 PROCEDURES, Power level dependent. License Amendment Yes 

PROGRAMS, AND Request PCN 602 requests that Technical 

MANUALS Specification 5.5.2.11 .b.1 be revised to add a 

footnote to require that compliance with the steam 

generator structural integrity performance criterion 

(SIPC) be demonstrated up to 70% rated thermal 

power. 

Remaining procedures, programs and manuals 

addressed in Section 5.5 are not power level 

dependent. 

5.6 SAFETY FUNCTION Not power level dependent. No 

DETERMINATION 

PROGRAM (SFDP) 

5.7 REPORTING Not power level dependent. Technical Specification No 

REQUIREMENTS 5.7.1.5 requires Core Operating Limits Report 

safety analyses to address operation at Rated 

Thermal Power. Refer to License Amendment 

Request PCN 602 commitment regarding Technical 

Specification 5.7.2.c Steam Generator Program 

Special Report. Remaining reporting requirements 

addressed in Section 5.7 are not impacted. 

5.8 HIGH RADIATION Not poWer level dependent. No 

AREA 

8 of 8