Text

Supplement to License Amendment Request for Full-Scope Implementation of the Alternate Source Term Technical Specification Change (TSC) Number 2001-07
	ML033370889
Person / Time
Site:	Oconee
Issue date:	11/20/2003
From:	Rosalyn Jones; Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML033370889 (55)
	v • d • e

P^ft Duke R.

A.

JONES r Powere Vice President A Duke Energy Company Duke Power 29672 / Oconee Nuclear Site 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax November 20, 2003 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Oconee Nuclear Station Docket Numbers 50-269, 270, and 287 Supplement to License Amendment Request for Full-Scope Implementation of the Alternate Source Term Technical Specification Change (TSC) Number 2001-07 On October 16, 2001, Duke Energy (Duke) submitted the license amendment request (LAR) for full-scope implementation of the Alternate Source Term (AST).

This LAR requested approval of the AST analysis methodology for Oconee Nuclear Station (ONS) that will support simplification of Ventilation System testing requirements during core alterations or movement of irradiated fuel.

Duke received additional questions from the NRC related to the AST LAR. Supplements to the LAR were submitted on May 20, 2002, September 12, 2002, November 21, 2002, January 27, 2003, and September 22, 2003.

In the original submittal, Penetration Room Ventilation System (PRVS) and Spent Fuel Pool Ventilation System (SFPVS) were removed from the Technical Specifications (TS).

After additional conversations with the NRC, Duke committed to maintaining these TS and supplemented the submittal on September 22, 2003.

The requirements of these TS were relaxed as a result of AST.

Duke also adopted TSTF-51 and the language associated with recently irradiated fuel to support the dose analysis assumption with respect to movement of irradiated fuel.

00 www. duke-energy.com

U. S. Nuclear Regulatory Commission November 20, 2003 Page 2 As a result of a conference call with the NRC on November 17, 2003, Duke will remove PRVS from the TS and will adopt TSTF-51 for SFPVS with the exception of the surveillance requirement to run the SFPVS trains. contains a re-typed copy of the TS. contains the marked-up copies of the TS. contains justification for the changes requested. contains the revised no significant hazards consideration.

Duke has committed to the following three modifications as a part of the AST LAR:

a dual air intake system to the Control Room; a reroute of LDST and LPI leakage to the RBES; and a passive caustic addition system.

These modifications will be completed on all three units by the end of 2005.

Pursuant to 10 CFR 50.91, a copy of this proposed license amendment is being sent to the State of South Carolina.

If there are any questions regarding this submittal, please contact Reene' Gambrell at (864) 885-3364.

Very tr

ours, R. AJes, Vice President Oconee Nuclear Site

U. S. Nuclear Regulatory Commission November 20, 2003 Page 3 cc:

Mr. L. N. Olshan, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-14 H25 Washington, D. C.

20555 Mr. L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission -

Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. C. Shannon Senior Resident Inspector Oconee Nuclear Station Mr. Henry Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201

U. S. Nuclear Regulatory Commission November 20, 2003 Page 4 R. A. Jones, being duly sworn, states that he is Vice President, Oconee Nuclear Site, Duke Energy Corporation, that he is authorized on the part of said Company to sign and file with the U. S. Nuclear Regulatory Commission this revision to the Renewed Facility Operating License Nos.

DPR-38, DPR-47, DPR-55; and that all the statements and matters set forth herein are true and correct to the best of his knowledge.

R. A. J~neKV 'Vice President Oconee Nuclear Site 0ibscribed and sworn to before me this 2 09day of

-rhea 2003 Kotary Public My Commission Expires:

ATTACHMENT 1 Duke Energy Corporation Retype of Technical Specifications REMOVE PAGE INSERT PAGE TS TOC iii 3.3.6-1 3.7.10-1 3.7.10-2 3.7.17-1 3.7.17-2 5.0-8 5.0-20 5.0-21 TSB TOC iv B 3.3.5-1 B 3.3.5-2 B 3.3.5-6 B 3.3.6-2 B 3.3.7-2 B 3.7.10-1 B 3.7.10-2 B 3.7.10-3 B 3.7.10-4 B 3.7.17-1 B 3.7.17-2 B 3.7.17-3 TS TOC iii 3.3.6-1 3.7.10-1 3.7.17-1 3.7.17-2

5. 0-8

5. 0-20 5.0-21 TSB TOC iv B 3.3.5-1 B 3.3.5-2 B 3.3.5-6 B 3.3.6-2 B 3.3.7-2 B 3.7.10-1 B 3.7.17-1 B 3.7.17-2 B 3.7.17-3

I' TABLE OF CONTENTS 3.4.6 RCS Loops - MODE 4........................................

3.4.6-1 3.4.7 RCS Loops - MODE 5, Loops Filled.

3.4.7-1 3.4.8 RCS Loops - MODE 5, Loops Not Filled........................................ 3.4.8-1 3.4.9 Pressurizer........................................

3.4.9-1 3.4.10 Pressurizer Safety Valves........................................

3.4.10-1 3.4.11 RCS Specific Activity........................................

3.4.11-1 3.4.12 Low Temperature Overpressure Protection (LTOP)

System......................................

3.4.12-1 3.4.13 RCS Operational LEAKAGE......................................

3.4.13-1 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage.................................... 3.4.14-1 3.4.15 RCS Leakage Detection Instrumentation......................................

3.4.15-1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)................................ 3.5.1-1 3.5.1 Core Flood Tanks (CFTs)......................................

3.5.1-1 3.5.2 High Pressure Injection......................................

3.5.2-1 3.5.3 Low Pressure Injection......................................

3.5.3-1 3.5.4 Borated Water Storage Tank (BWST)......................................

3.5.4-1 3.6 CONTAINMENT SYSTEMS......................................

3.6.1-1 3.6.1 Containment......................................

3.6.1-1 3.6.2 Containment Air Locks......................................

3.6.2-1 3.6.3 Containment Isolation Valves......................................

3.6.3-1 3.6.4 Containment Pressure......................................

3.6.4-1 3.6.5 Reactor Building Spray and Cooling System...................................... 3.6.5-1 3.7 PLANT SYSTEMS......................................

3.7.1-1 3.7.1 Main Steam Relief Valves (MSRVs)......................................

3.7.1-1 3.7.2 Turbine Stop Valves (TSVs)......................................

3.7.2-1 3.7.3 Main Feedwater Control Valves (MFCVs), and Startup Feedwater Control Valves (SFCVs)....................................

3.7.3-1 3.7.4 Atmospheric Dump Valve (ADV) Flow Paths.................................... 3.7.4-1 3.7.5 Emergency Feedwater (EFW) System....................................

3.7.5-1 3.7.6 Upper Surge Tank (UST) and Hotwell (HW).................................... 3.7.6-1 3.7.7 Low Pressure Service Water (LPSW) System................................... 3.7.7-1 3.7.8 Emergency Condenser Circulating Water (ECCW)........................... 3.7.8-1 3.7.9 Control Room Ventilation System (CRVS) Booster Fans..........................

3.7.9-1 3.7.10 Not Used..........................

3.7.10-1 3.7.11 Spent Fuel Pool Water Level..........................

3.7.11-1 3.7.12 Spent Fuel Pool Boron Concentration..........................

3.7.12-1 3.7.13 Fuel Assembly Storage..........................

3.7.13-1 OCONEE UNITS 1, 2, & 3 ill Amendment Nos. XXX, XXX, & XXX I

ESPS Manual Initiation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Engineered Safeguards Protective System (ESPS) Manual Initiation LCO 3.3.6 Two manual initiation channels of each one of the ESPS Functions below shall be OPERABLE:

a.

High Pressure Injection, Reactor Building (RB) Non-Essential Isolation, Keowee Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input (ES Channels 1 and 2);

b.

Low Pressure Injection (ES Channels 3 and 4);

c.

RB Cooling and RB Essential Isolation (ES Channels 5 and 6); and

d.

RB Spray (ES Channels 7 and 8).

APPLICABILITY:

MODES 1 and 2, MODES 3 and 4 when associated engineered safeguard equipment is required to be OPERABLE.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more ESPS A.1 Restore channel to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Functions with one OPERABLE status.

channel inoperable.

(continued)

OCONEE UNITS 1, 2, & 3 3.3.6-1 Amendment Nos. XXX, XXX & XXX I

Not Used l 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Not Used I

OCONEE UNITS 1, 2, & 3 3.7.10-1 Amendment Nos. XXX, XXX, & XXX I

SFPVS 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Spent Fuel Pool Ventilation System (SFPVS)

LCO 3.7.17 APPLICABILITY:

Two SFPVS trains shall be OPERABLE.

During movement of recently irradiated fuel assemblies in the spent fuel pool.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One SFPVS train A.1 Place OPERABLE Immediately inoperable.

SFPVS train in operation.

OR A.2 Suspend movement of Immediately recently irradiated fuel assemblies in the spent fuel pool.

B. Two SFPVS trains B.1 Suspend movement of Immediately inoperable.

recently irradiated fuel assemblies in the spent fuel pool.

OCONEE UNITS 1, 2, & 3 3.7.17-1 Amendment Nos. XXX, XXX, & XXX I

SFPVS 3.7.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Operate each SFPVS train for 2 15 minutes.

31 days prior to movement of recently irradiated fuel assemblies SR 3.7.17.2 Perform required SFPVS filter testing in In accordance with the accordance with the Ventilation Filter VFTP Testing Program (VFTP).

OCONEE UNITS 1, 2, & 3 3.7.1 7-2 Amendment Nos. XXX, XXX, & XXX I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.2 Containment Leakage Rate Testing Program (continued)

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. Containment system visual examinations required by Regulatory Guide 1.163, Regulatory Position C.3 shall be performed as follows:

1.

Accessible concrete surfaces and post-tensioning system component surfaces of the concrete containment shall be visually examined prior to initiating SR 3.6.1.1 Type A test. These visual examinations, or any portion thereof, shall be performed no earlier than 90 days prior to the start of refueling outages in which Type A tests will be performed. The validity of these visual examinations will be evaluated should any event or condition capable of affecting the integrity of the containment system occur between the completion of the visual examinations and the Type A test.

2.

Accessible interior and exterior surfaces of metallic pressure retaining components of the containment system shall be visually examined at least three times every ten years, including during each shutdown for SR 3.6.1.1 Type A test, prior to initiating the Type A test.

Type B and C testing shall be implemented in the program in accordance with the requirements of 10 CFR 50, Appendix J, Option A.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 59 psig.

The maximum allowable containment leakage rate, La, at Pa, shall be 0.20% of the containment air weight per day.

Leakage rate acceptance criterion is:

a.

Containment leakage rate acceptance criterion is

1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and Type C tests, and

< 0.75 La for Type A tests; The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

OCONEE UNITS 1, 2, & 3 5.0-8 Amendment Nos. XXX, XXX, & XXX I

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.12 Ventilation Filter Testinq Program (VFTP)

A program shall be established to implement the following required testing of filter ventilation systems. CRVS testing will be conducted at the frequencies specified in Regulatory Guide 1.52, Revision 2.

The VFTP is applicable to the Control Room Ventilation System (CRVS) Booster Fan Trains and the Spent Fuel Pool Ventilation System (SFPVS).

a.

Demonstrate, for the CRVS Booster Fan Trains, that a DOP test of the HEPA filters shows 2 99.5% removal when tested at in accordance with ANSI N510-1975 at the system design flow rate +/- 10%.

b.

Demonstrate, for the CRVS Booster Fan Trains, that a halogenated hydrocarbon test of the carbon adsorber shows 2 99% removal when tested at in accordance with ANSI N510-1975 at the system design flow rate +/- 10%.

OCONEE UNITS 1, 2, & 3 5.0-20 Amendment Nos. XXX, XXX, & XXX I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Ventilation Filter Testing Program (VFTP) (continued)

c.

Demonstrate, for the CRVS Booster Fan Trains and SFPVS, that a laboratory test of a sample of the carbon adsorber shows 2 97.5% and 90% radioactive methyl iodide removal when tested in accordance with ASTM D3803-1989 (300C, 95% RH), respectively.

d.

Demonstrate, for the CRVS Booster Fan Trains, that the pressure drop across the pre-filter is < 1 in. of water'and the pressure drop across the HEPA filters is < 2 in. of water at the system design flow rate +/- 10%.

e.

Demonstrate, for the SFPVS, that a dioctyl phthalate (DOP) test of the high efficiency particulate air (HEPA) filters shows 2 90% removal when tested in accordance with ANSI N510-1975 at the system design flow rate

+/- 20%.

f.

Demonstrate, for the SFPVS, that a halogenated hydrocarbon test of the carbon adsorber shows Ž 90% removal when tested in accordance with ANSI N510-1975 at the system design flow rate +/- 20%.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.13 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the waste gas holdup tanks and the quantity of radioactivity contained in waste gas holdup tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined. The liquid radwaste quantities shall be determined by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

OCONEE UNITS 1, 2, & 3 5.0-21 Amendment Nos. XXX, XXX, & XXX I

TABLE OF CONTENTS B 3.7 PLANT SYSTEMS (continued)

B 3.7.9 Control Room Ventilation System (CRVS) Booster Fans......................................

B 3.7.9-1 B 3.7.10 Not Used......................................

B 3.7.10-1 B 3.7.11 Spent Fuel Pool Water Level......................................

B 3.7.11-1 B 3.7.12 Spent Fuel Pool Boron Concentration........................................ B 3.7.12-1 B 3.7.13 Fuel Assembly Storage........................................ B 3.7.13-1 B 3.7.14 Secondary Specific Activity......................................

B 3.7.14-1 B 3.7.15 Decay Time for Fuel Assemblies in Spent Fuel Pool (SFP)........................................ B 3.7.15-1 B 3.7.16 Control Room Area Cooling Systems (CRACS)........................... B 3.7.16-1 B 3.7.17 Spent Fuel Pool Ventilation System (SFPVS).............................. B 3.7.17-1 B 3.8 ELECTRICAL POWER SYSTEMS........................................ B 3.8.1-1 B 3.8.1 AC Sources - Operating........................................ B 3.8.1-1 B 3.8.2 AC Sources - Shutdown........................................ B 3.8.2-1 B 3.8.3 DC Sources - Operating........................................ B 3.8.3-1 B 3.8.4 DC Sources - Shutdown........................................ B 3.8.4-1 B 3.8.5 Battery Cell Parameters........................................ B 3.8.5-1 B 3.8.6 Vital Inverters - Operating......................................

B 3.8.6-1 B 3.8.7 Vital Inverters - Shutdown......................................

B 3.8.7-1 B 3.8.8 Distribution Systems - Operating......................................

B 3.8.8-1 B 3.8.9 Distribution Systems - Shutdown......................................

B 3.8.9-1 B 3.9 REFUELING OPERATIONS........................................ B 3.9.1-1 B 3.9.1 Boron Concentration......................................

B 3.9.1-1 B 3.9.2 Nuclear Instrumentation........................................ B 3.9.2-1 B 3.9.3 Containment Penetrations......................................

B 3.9.3-1 B 3.9.4 Decay Heat Removal (DHR) and Coolant Circulation - High Water Level....

B 3.9.4-1 B 3.9.5 Decay Heat Removal (DHR) and Coolant Circulation - Low Water Level..................................

B 3.9.5-1 B 3.9.6 Fuel Transfer Canal Water Level.................................... B 3.9.6-1 B 3.9.7 Unborated Water Source Isolation Valves................................... B 3.9.7-1 B 3.10 STANDBY SHUTDOWN FACILITY.................................... B 3.10.1 -1 B 3.10.1 Standby Shutdown Facility (SSF).................................... B 3.10.1 -1 B 3.10.2 Standby Shutdown Facility (SSF) Battery Cell Parameters.....

B 3.10.2-1 OCONEE UNITS 1, 2, & 3 iv Amendment Nos. XXX, XXX, & XXX I

ESPS Analog Instrumentation B 3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Engineered Safeguards Protective System (ESPS) Analog Instrumentation BASES BACKGROUND The ESPS initiates necessary safety systems, based on the values of selected unit Parameters, to protect against violating core design limits and to mitigate accidents.

ESPS actuates the following systems:

X High pressure injection (HPI);

X Low pressure injection (LPI);

X Reactor building (RB) cooling; X

RB Spray; X

RB Isolation; and X

Keowee Hydro Unit Emergency Start.

The ESPS operates in a distributed manner to initiate the appropriate systems. The ESPS does this by determining the need for actuation in each of three analog channels monitoring each actuation Parameter. Once the need for actuation is determined, the condition is transmitted to digital automatic actuation logic channels, which perform the two-out-of-three logic to determine the actuation of each end device. Each end device has its own automatic actuation logic, although all digital automatic actuation logic channels take their signals from the same bistable in each channel for each Parameter.

Four Parameters are used for actuation:

X Low Reactor Coolant System (RCS) Pressure; X

Low Low RCS Pressure; X

High RB Pressure; and X

High High RB Pressure.

OCONEE UNITS 1, 2, & 3 B 3.3.5-1 Amendment Nos. XXX, XXX, & XXX I

ESPS Analog Instrumentation B 3.3.5 BASES BACKGROUND (continued)

LCO 3.3.5 covers only the analog instrumentation channels that measure these Parameters. These channels include all intervening equipment necessary to produce actuation before the measured process Parameter exceeds the limits assumed by the accident analysis. This includes sensors, bistable devices, operational bypass circuitry, and output relays.

LCO 3.3.6, "Engineered Safeguards Protective System (ESPS) Manual Initiation," and LCO 3.3.7, "Engineered Safeguards Protective System (ESPS) Digital Automatic Actuation Logic Channels," provide requirements on the manual initiation and digital automatic actuation logic Functions.

The ESPS contains three analog channels. Each analog channel provides input to digital logic channels that initiate equipment with a two-out-of-three logic on each digital logic channel. Each analog channel includes inputs from one analog instrumentation channel of Low RCS Pressure, Low Low RCS Pressure, High RB Pressure, and High High RB Pressure. Digital automatic actuation logic channels combine the three analog channel trips to actuate the individual Engineered Safeguards (ES) components needed to initiate each ES System. Figure 7.5, UFSAR, Chapter 7 (Ref. 1),

illustrates how analog instrumentation channel trips combine to cause digital logic channel trips.

The following matrix identifies the analog instrumentation (measurement) channels and the Digital Automatic Actuation Logic Channels actuated by each.

Digital Actuated FCS RCS l

RB RB Logic Channels Systems/

PRESS PRESS l

PRESS PRESS Functions LOW LOW HIGH HIGH LOW HIGH 1 and 2 HPI and RB Non-Essential X

X Isolation, Keowee Emergency Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input 3 and 4 LPI and RB Essential X

X Isolation 5 and 6 RB Cooling and RB X

Essential Isolation.

7 and 8 RB Spray X

The ES equipment is generally divided between the two redundant digital actuation logic channels. The division of the equipment between the two digital actuation logic channels is based on the equipment redundancy and OCONEE UNITS 1, 2, & 3 B 3.3.5-2 Amendment Nos. XXX, XXX, & XXX I

ESPS Analog Instrumentation B 3.3.5 BASES APPLICABLE Reactor Building Spray. Reactor Building Cooling, and SAFETY ANALYSES Reactor Building Isolation (continued)

The ESPS actuation of the RB coolers and RB Spray have been credited in RB analysis for LOCAs, both for RB performance and equipment environmental qualification pressure and temperature envelope definition.

Accident dose calculations have credited RB Isolation and RB Spray.

Keowee Hydro Unit Emergency Start The ESPS initiated Keowee Hydro Unit Emergency Start has been included in the design to ensure that emergency power is available throughout the limiting LOCA scenarios.

The small break LOCA analyses assume a conservative 48 second delay time for the actuation of HPI and LPI in UFSAR, Chapter 15 (Ref. 4). The large break LOCA analyses assume LPI flow starts in 38 seconds while full LPI flow does not occur until 15 seconds later, or 53 seconds total (Ref. 4). 7his delay time includes allowances for Keowee Hydro Unit starting, Emergency Core Cooling Systems (ECCS) pump starts, and valve openings. Similarly, the RB Cooling, RB Isolation, and RB Spray have been analyzed with delays appropriate for the entire system analyzed.

Accident analyses rely on automatic ESPS actuation for protection of the core temperature and containment pressure limits and for limiting off site dose levels following an accident. These include LOCA, and MSLB events that result in RCS inventory reduction or severe loss of RCS cooling.

The ESPS channels satisfy Criterion 3 of 10 CFR 50.36 (Ref. 5).

LCO The LCO requires three analog channels of ESPS instrumentation for each Parameter in Table 3.3.5-1 to be OPERABLE in each ESPS digital automatic actuation logic channel. Failure of any instrument renders the affected analog channel(s) inoperable and reduces the reliability of the affected Functions.

OCONEE UNITS 1. 2. & 3 B 3.3.5-6 Amendment Nos. XXX, XXX, & XXX I

ESPS Manual Initiation B 3.3.6 BASES APPLICABLE The ESPS manual initiation ensures that the control room operator can SAFETY ANALYSES rapidly initiate ES Functions. The manual initiation trip Function is required (continued) as a backup to automatic trip functions and allows operators to initiate ESPS whenever any parameter is rapidly trending toward its trip setpoint.

The ESPS manual initiation functions satisfy Criterion 3 of 10 CFR 50.36 (Ref. 1).

LCO Two ESPS manual initiation channels of each ESPS Function shall be OPERABLE whenever conditions exist that could require ES protection of the reactor or RB. Two OPERABLE channels ensure that no single random failure will prevent system level manual initiation of any ESPS Function. The ESPS manual initiation Function allows the operator to initiate protective action prior to automatic initiation or in the event the automatic initiation does not occur.

The required Function is provided by two associated channels as indicated in the following table:

Function Associated Channels HPI and RB Non-Essential 1 & 2 Isolation, Keowee Emergency Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input LPI 3&4 RB Cooling and RB Essential 5 & 6 isolation RB Spray 7&8 APPLICABILITY The ESPS manual initiation Functions shall be OPERABLE in MODES 1 and 2, and in MODES 3 and 4 when the associated engineered safeguard equipment is required to be OPERABLE. The manual initiation channels are required because ES Functions are designed to provide protection in these MODES. ESPS initiates systems that are either reconfigured for decay heat removal operation or disabled while in MODES 5 and 6.

Accidents in these MODES are slow to develop and would be mitigated by manual operation of individual components. Adequate time is available to evaluate unit conditions and to respond by manually operating the ES components, if required.

OCONEE UNITS 1, 2, & 3 B 3.3.6-2 Amendment Nos. XXX, XXX & XXX I

ESPS Automatic Digital Actuation Logic Channels B 3.3.7 BASES BACKGROUND Hydro Unit startup and loading, ECCS pump starts, and valve openings.

(continued)

Similarly, the reactor building (RB) Cooling, RB Isolation, and RB Spray have been analyzed with delays appropriate for the entire system.

The ESPS automatic initiation of Engineered Safeguards (ES) Functions to mitigate accident conditions is assumed in the accident analysis and is required to ensure that consequences of analyzed events do not exceed the accident analysis predictions. Automatically actuated features include HPI, LPI, RB Cooling, RB Spray, and RB Isolation.

APPLICABLE Accident analyses rely on automatic ESPS actuation for protection of the SAFETY ANALYSES core and RB and for limiting off site dose levels following an accident. The digital automatic actuation logic is an integral part of the ESPS.

The ESPS digital automatic actuation logic channels satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LCO The digital automatic actuation logic channels are required to be OPERABLE whenever conditions exist that could require ES protection of the reactor or the RB. This ensures automatic initiation of the ES required to mitigate the consequences of accidents.

The required Function is provided by two associated digital channels as indicated in the following table:

Function Associated Channels HPI and RB Non-Essential 1 & 2 Isolation, Keowee Emergency Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input LPI and RB Essential isolation 3 & 4 RB Cooling and RB Essential 5 & 6 isolation RB Spray 7&8 OCONEE UNITS 1, 2, & 3 B 3.3.7-2 Amendment Nos. XXX, XXX, & XXX I

Not Used I B 3.7.1 0 B 3.7 PLANT SYSTEMS B 3.7.10 Not Used I

OCONEE UNITS 1, 2, & 3 B 3.7.1 0-1 Amendment Nos. XXX, XXX, & XXX I

SFPVS B 3.7.17 B 3.7 PLANT SYSTEMS B 3.7.17 Spent Fuel Pool Ventilation System (SFPVS)

BASES BACKGROUND Ventilation air for the Spent Fuel Pool Area is supplied by an air handling unit which consists of roughing filters, steam heating coil, cooling coil supplied by low pressure service water, and a centrifugal fan. In the normal mode of operation, the air from the Spent Fuel Pool Area is exhausted directly to the unit vents by the general Auxiliary Building exhaust fans. The filtered exhaust system consists of a single filter train and two 100 percent capacity vane axial fans. The filter train utilized is the Reactor Building Purge Filter Train. The Unit 2 Reactor Building purge filter train is used for the combined Unit 1 and 2 Spent Fuel Pool Ventilation System, The Unit 3 Reactor Building purge filter train is used for the Unit 3 SFP Ventilation System. The filter train is comprised of prefilters, HEPA filters, and charcoal filters. To control the direction of air flow, i.e., to direct the air from the Fuel Pool Area to the Reactor Building Purge Filter Train, a series of pneumatic motor operated dampers are provided along with a crossover duct from the Fuel Pool to the filter train.

The SFPVS is discussed in the UFSAR, Section 9.4.2, (Ref. 1).

APPLICABLE SAFETY ANALYSES The analysis of the limiting fuel handling accident, the cask drop accident, given in Reference 2, assumes that a certain number of fuel assemblies are damaged. The DBA analysis for the cask drop accident, does not assume operation of the SFPVS in order to meet the requirements of 10 CFR 50.67 (Ref. 4). These assumptions and the analysis are consistent with the guidance provided in Regulatory Guide 1.183 (Ref. 3).

I The SFPVS does not satisfy the criteria in 10 CFR 50.36. The SFPVS is retained in this specification for ALARA purposes.

LCO With the adoption of the alternate source term and the installation of various plant modifications, SFPVS is not credited in dose analysis calculations. Therefore, there are no specific operability requirements for this system.

OCONEE UNITS 1, 2, & 3 B 3.7.17-1 Amendment Nos. XXX, XXX, & XXX I

SFPVS I B 3.7.17 BASES LCO An SFPVS train is considered OPERABLE when its associated:

(continued)

1.

Fan is OPERABLE;

2.

Filter trains are intact; and

3.

Ductwork and dampers are OPERABLE, and air flow can be maintained.

APPLICABILITY During movement of recently irradiated fuel assemblies in the fuel handling area, the SFPVS shall be OPERABLE.

I ACTIONS A.1 and A.2 With one SFPVS train inoperable, the OPERABLE SFPVS train must be started immediately with its discharge through the associated reactor building purge filter or recently irradiated fuel movement in the spent fuel pool suspended. This action ensures that the remaining train is OPERABLE, and that any active failures will be readily detected.

If the system is not placed in operation, this action requires suspension of recently irradiated fuel movement, which precludes a fuel handling accident. This action does not preclude the movement of recently irradiated fuel assemblies to a safe position.

OCONEE UNITS 1, 2, & 3 B 3.7.17-2 Amendment Nos. XXX, XXX, & XXX I

SFPVS B 3.7.17 BASES ACTIONS B.1 (continued)

When two trains of the SFPVS are inoperable during movement of recently irradiated fuel in the spent fuel pool, the unit must be placed in a condition in which the LCO does not apply. This Action involves immediately suspending movement of recently irradiated fuel assemblies in the spent fuel pool. This does not preclude the movement of recently irradiated fuel to a safe position.

SURVEILLANCE SR 3.7.17.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train 31 days prior to moving recently irradiated fuel assemblies provides an adequate check on this system. The system is no longer credited in dose analysis calculations and is not required to maintain 10 CFR 50.67 dose limits, but is required for ALARA purposes.

SR 3.7.17.2 This SR verifies that the required SFPVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP.

REFERENCES

1.

UFSAR, Section 9.4.2.

2.

UFSAR, Section 15.11.

3.

Regulatory Guide 1.183.

4.

10 CFR 50.67.

5.

Dose Calculations.

I OCONEE UNITS 1, 2, & 3 B 3.7.17-3 Amendment Nos. XXX, XXX, & XXX I

ATTACHMENT 2 Duke Energy Corporation Mark-up of Technical Specifications

TABLE OF CONTENTS 3.4.6 3.4.7 3.4.8 3.4.9 3.4.10 3.4.11 3.4.12 3.4.13 3.4.14 3.4.15 3.5 3.5.1 3.5.2 3.5.3 3.5.4 3.6 3.6.1 3.6.2 3.6.3 3.6.4 3.6.5 RCS Loops - MODE 4...................................

3.4.6-1 RCS Loops - MODE 5, Loops Filled...................................

3.4.7-1 RCS Loops - MODE 5, Loops Not Filled....................................

3.4.8-1 Pressurizer....................................

3.4.9-1 Pressurizer Safety Valves....................................

3.4.10-1 RCS Specific Activity....................................

3.4.11-1 Low Temperature Overpressure Protection (LTOP)

System........................................

3.4.12-1 RCS Operational LEAKAGE.......................................

3.4.13-1 RCS Pressure Isolation Valve (PIV) Leakage.................................... 3.4.14-1 RCS Leakage Detection Instrumentation.......................................

3.4.15-1 EMERGENCY CORE COOLING SYSTEMS (ECCS)................................ 3.5.1-1 Core Flood Tanks (CFTs).......................................

3.5.1-1 High Pressure Injection.......................................

3.5.2-1 Low Pressure Injection.......................................

3.5.3-1 Borated Water Storage Tank (BWST).......................................

3.5.4-1 CONTAINMENT SYSTEMS.......................................

3.6.1-1 Containment.......................................

3.6.1-1 Containment Air Locks........................................

3.6.2-1 Containment Isolation Valves........................................

3.6.3-1 Containment Pressure........................................

3.6.4-1 Reactor Building Spray and Cooling System...................................... 3.6.5-1 PLANT SYSTEMS........................................

3.7.1-1 Main Steam Relief Valves (MSRVs)........................................

3.7.1-1 Turbine Stop Valves (TSVs)........................................

3.7.2-1 Main Feedwater Control Valves (MFCVs), and Startup Feedwater Control Valves (SFCVs)....................................

3.7.3-1 Atmospheric Dump Valve (ADV) Flow Paths................................... 3.7.4-1 Emergency Feedwater (EFW) System....................................

3.7.5-1 Upper Surge Tank (UST) and Hotwell (HW).................................... 3.7.6-1 Low Pressure Service Water (LPSW) System................................... 3.7.7-1 Emergency Condenser Circulating Water (ECCW)........................... 3.7.8-1 Control Room Ventilation System (CRVS) Booster Fans.................................

3.7.9-1 Cd

_eet, Roi Vy (PF 3.7.10-1 Spent Fuel Pool Water Level.3.7.11-1 Spent Fuel Pool Boron Concentration.3.7.12-1 Fuel Assembly Storage.

3.7.13-1 3.7 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 3.7.8 3.7.9 I

3.7.10 3.7.11 3.7.12 3.7.13 LJO s

OCONEE UNITS 1, 2, & 3 AXmn XNXo )OC OCONEE UNITS 1,2,

& 3 iii

~Amendment Nos. 83&0 &30, & 334 TABLE OF CONTENTS B 3.7 PLANT SYSTEMS (continued)

B 3.7.9 Control Room Ventilation System (CRVS) Booster Fans.........................................

B 3.7.9-1 B 3.7.10 Nst sc4 Pnti Ro tilatiO Sytm

_............................ B 3.7.10-1 B 3.7.11 Spent Fuel Pool Water Level.........................................

B 3.7.11-1 B 3.7.12 Spent Fuel Pool Boron Concentration......................................... B 3.7.12-1 B 3.7.13 Fuel Assembly Storage........................................... B 3.7.13-1 B 3.7.14 Secondary Specific Activity.........................................

B 3.7.14-1 B 3.7.15 Decay Time for Fuel Assemblies in Spent Fuel Pool (SFP)........................................ B 3.7.15-1 B 3.7.16 Control Room Area Cooling Systems (CRACS)........................... B 3.7.16-1 B 3.7.17 Spent Fuel Pool Ventilation System (SFPVS).............................. B 3.7.17-1 B 3.8 ELECTRICAL POWER SYSTEMS........................................ B 3.8.1-1 B 3.8.1 AC Sources - Operating........................................ B 3.8.1-1 B 3.8.2 AC Sources - Shutdown........................................ B 3.8.2-1 B 3.8.3 DC Sources - Operating........................................ B 3.8.3-1 B 3.8.4 DC Sources - Shutdown........................................ B 3.8.4-1 B 3.8.5 Battery Cell Parameters........................................ B 3.8.5-1 B 3.8.6 Vital Inverters - Operating......................................

B 3.8.6-1 B 3.8.7 Vital Invertors - Shutdown......................................

B 3.8.7-1 B 3.8.8 Distribution Systems - Operating......................................

B 3.8.8-1 B 3.8.9 Distribution Systems - Shutdown......................................

B 3.8.9-1 B 3.9 REFUELING OPERATIONS......................................

B 3.9.1-1 B 3.9.1 Boron Concentration......................................

B 3.9.1-1 B 3.9.2 Nuclear Instrumentation........................................ B 3.9.2-1 B 3.9.3 Containment Penetrations......................................

B 3.9.3-1 B 3.9.4 Decay Heat Removal (DHR) and Coolant Circulation - High Water Level....

B 3.9.4-1 B 3.9.5 Decay Heat Removal (DHR) and Coolant Circulation - Low Water Level..................................

B 3.9.5-1 B 3.9.6 Fuel Transfer Canal Water Level.................................... B 3.9.6-1 B 3.9.7 Unborated Water Source Isolation Valves................................... B 3.9.7-1 B 3.10 STANDBY SHUTDOWN FACILITY..................................

B 3.10.1-1 B 3.10.1 Standby Shutdown Facility (SSF)..................................

B 3.1 0.1-1 B 3.10.2 Standby Shutdown Facility (SSF) Battery Cell Parameters.....

B 3.10.2-1 CNE3vAs 0

xx OCONEE UNITS 1, 2, & 3 iv Amendment Nos. ye9, 309, & 309l

ESPS Manual Initiation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Engineered Safeguards Protective System (ESPS) Manual Initiation LCO 3.3.6 Two manual initiation channels of each one of the ESPS Functions below shall be OPERABLE:

a.

High Pressure Injection, Reactor Building (RB) Non-Essential Isolation, Keowee Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input (ES Channels 1 and 2);

I APPLICABILITY:

MODES 1 and 2, MODES 3 and 4 when associated engineered safeguard equipment is required to be OPERABLE.

ACTIONS IJLJ r7 -------------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more ESPS A.1 Restore channel to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Functions with one OPERABLE status.

channel inoperable.

(continued)

OCONEE UNITS 1. 2. & 3 Aedexxx x XX Amendment Nos.329, 62&& K4 1 3.3.6-1

Mot L seo(

3.7.10 3.7 PLANT SYSTEMS 3.7.10 System.(PRV-L&)

tNot UseAl I

h rP-d nI-n il

~ n i it n LCO 3.7.10 AP LICABILITY:

ACTIONS Two PRVS trains shall be OPERABLE.

MODES 1, 2, 3, and 4.

CoI REQUIRED ACTION COMPLETION TIME 4.

Restore PRVS train to OPERABLE status.

7 days Inoi B.

Required Action and associated Completion Time not met.

+

nMODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

)'E 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each PRVS train for > 15 minutes.

31 days SR 3.7.10.2 Perform required PRVS filter testing in In ac dance with the accordance with the Ventilation Filter Testing VFTP Program (VFTP).

(c tinued)

Amendment Nos. AO, 8AG, &

x) x yJ XX OCONEE UNITS 1,2, &3 3.7.10-1

SURVEILLANCE REQU ENTS (continued)

-PPAV&

SURtEILLANCE FREQUENCY SR 3.7.10.3 Verify each P t

es on an actual 18 months or simulated atuati.

SR 3.7.10.4 Verify one PRVS t in ca in a 18 months on a negative pressure -0.06 i ches water gauge STAGGERED TEST relative to atmospherc pre rnBASIS operation at a flow ra of 2 06'~pf and S 1 100 cfm.\\\\\\

SR 3.7.10.5 Verify the PRVS filter cooing byp ss\\

18 months valve can be opened.

4)GGNEE-HMff61-,2-,& --740do

-Amendment Ncs. 300, 300, & 300

SFPVS 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Spent Fuel Pool Ventilation System (SFPVS)

LCO 3.7.17 APPLICABILITY:

Twn 5;FPV.1 trnin-, shaII hp OPFRARL-F I

-X-------------X---------

-NOTE --------

1.

LO 03.0.3 is not applicaple.\\\\l

2.

Not pplicable uring rer king oper tions with o fuel in t spen fuel ool.

During movement ofifueqin the spent fuel pool.

Se abe S D'

'ring capne operatiorih th-lKepoo ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One SFPVS train A.1 Place OPERABLE Immediately inoperable.

SFPVS train in operation.

OR A.2x'i Suspend movement of Immediately rce.1t+J~fueln the spent fuel Irrc pool kS.Sear 61ssC.S AND A.2.2 Suspend crane -

imediately-

...epations-with-loads-

.evef-thespent-fue&

Pooh-(continued)

Amendment Nos..X &

300-OCONEE UNITS 1, 2, & 3 3.7.1 7-1

SFPVS 3.7.17 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two SFPVS trains B.1.1 Suspend movement of Immediately inoperable.

in the spent fuel

-pool.-

a0.1.2

~

cail 4Immediatey

-operations wfti-h oads-e-4he-pentftael-

-peel.-

/31 d.QjS pri9 4

t asseR blieR SURVEILLANCE REQUIREMENTS 11 SURVEILLANCE FREQUENCY

_~

~~ i=

SR 3.7.17.2 Perform required SFPVS filter testing in In accordance with the accordance with the Ventilation Filter VFTP Testing Program (VFTP).

OCONEE UNITS 1, 2, & 3 3.7.1 7-2 Amendment Nos. 8S, 800, &

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.2 Containment Leakage Rate Testing Proqram (continued)

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program," dated September 1995. Containment system visual examinations required by Regulatory Guide 1.163. Regulatory Position C.3 shall be performed as follows:

1.

Accessible concrete surfaces and post-tensioning system component surfaces of the concrete containment shall be visually examined prior to initiating SR 3.6.1.1 Type A test. These visual examinations, or any portion thereof, shall be performed no earlier than 90 days.prior to the start of refueling outages in which Type A tests will be performed. The validity of these visual examinations will be evaluated should any event or condition capable of affecting the integrity of the containment system occur between the completion of the visual examinations and the Type A test.

2.

Accessible interior and exterior surfaces of metallic pressure retaining components of the containment system shall be visually examined at least three times every ten years, including during each shutdown for SR 3.6.1.1 Type A test, prior to initiating the Type A test.

Type B and C testing shall be implemented in the program in accordance with the requirements of 10 CFR 50, Appendix J, Option A.

The peak calculated containment internal pressure for the design basi of coolant accident, Pa, is 59 psig.

The maximum al wable containment leak e rate, L,, at Pa, hall be 0-2 W/o of the containment ir weight per day.

r r;keoc ;.^

DA16 Leakage rate ceptance)Vlteria-,aF6

a.

Containm leak accept criterion is

1.0 La. During the first unit startup following testi1ccordance with this program, the leakage rate ne~ptace criteria L for the Type B and Type C tests, and

0.75 La for Tyetests; Th of SR 3.0.3 are applicable to the Cotaakage Rate Testing Progr OCONEE UNITS 1. 2, & 3 5.0-8 Amendment Nos.

4W,34-0,3 I

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Secondary Water Chemistry This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control points for these variables;

b.

Identification of the procedures used to measure the values of the critical variables;

c.

Identification of process sampling points;

d.

Procedures for the recording and management of data;

e.

Procedures defining corrective actions for all off control point chemistry conditions; and

f.

A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.

5.5.12 Ventilation Filter -estin Pro ra A program shall be established to implement the following required testing of filte ~ntilation systemsa th rqece pcfied in Regulatory Guide 1.52, R sion 2.

0

{

=

i 5

The VFTP is applicable to the renetrtiei-onoVentilation-System-(PRVS).-he Control Room Ventilation System (CRVS) Booster Fan Trainsyand the Spent Fuel P6ol Ventilation System (SFPVS).

al--Demonstrate-fotcsPRVS-that-e-diootyl-phthalate-3GPI)-test-of-the-high effielency-padiculate-air.(HE-PWfilters-shows-i-99%-removal-whentested-in-acsrdance-with-ANSI-N51O-97§-at-thesystem-design-flow-rate

-44

,kA.

Demonstrate, for the CRVS Booster Fan Trains, that a DOP test of the

/HEPA filters shows Ž 99.5% removal when tested at in accordance with

.ANSI N510-1975 at the system design flow rate +/- 10%.

X C~-arbon ddalsor bersws-z-9931reoahwhe t~estedirn-aeeerdaneezvith)

OCONEE UNITS 1. 2. & 3 5.0-21 Amendment Nos.

I+3O51 I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 5.5.13

,Ventilation Filter Testino Proaram (VFTP) (continued)

, fiv.

<Demonstrate, for the CRVS Booster Fan Trains, that a halogenated hydrocarbon test of the carbon adsorber shows 2 99% removal when tested at in accordance with ANSI N51 0-1975 at the system design flow rate +/- 10%.

1 pC'. Demonstrate, for the CRVS laboratory test of a sample '

radioactive methyl to;Cde rei D3803-1989 (30C, 9_% R..

flo~ji4Iw rate,46 (W.

emon tra e, f r t e C VS B ost r F n Trains, that the pressure ro across the pre-filter is

1 in. of water and the pressure drop across the HEPA filters is < 2 in. of water at the system design flow rate +/- 10%.

5 Demonstrate, for the SFPVS, that a dioctyl phthaJ~' pIg) test of the high efficiency particulate air (HEPA) filters sho

>sŽ9%

r moval when Li"terdalccordance with ANSI N510-1975 at thdesign flow rate The provisions of SR 3.0.2 and SR 3.0.3 are frequencies.

Explosive Gas and Storaae Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the waste gas holdup tanks and the quantity of radioactivity contained In waste gas holdup tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined. The liquid radwaste quantities shall be determined by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

OCONEE UNITS 1, 2, & 3 5.0-22 Amendment Nos. 310, 310, 310 I

ESPS Analog Instrumentation B 3.3.5 B 3.3 INSTRUMENTATION B 3.3.5 Engineered Safeguards Protective System (ESPS) Analog Instrumentation BASES BACKGROUND The ESPS initiates necessary safety systems, based on the values of selected unit Parameters, to protect against violating core design limits and to mitigate accidents.

ESPS actuates the following systems:

High pressure injection (HPI);

Low pressure injection (LPI);

RB Isolation; and Keowee Hydro Unit Emergency Start.

The ESPS operates in a distributed manner to initiate the appropriate systems. The ESPS does this by determining the need for actuation in each of three analog channels monitoring each actuation Parameter. Once the need for actuation is determined, the condition is transmitted to digital automatic actuation logic channels, which perform the two-out-of-three logic to determine the actuation of each end device. Each end device has its own automatic actuation logic, although all digital automatic actuation logic channels take their signals from the same bistable in each channel for each Parameter.

Four Parameters are used for actuation:

Low Reactor Coolant System (RCS) Pressure; Low Low RCS Pressure; High RB Pressure; and High High RB Pressure.

OCONEE UNITS 1, 2, & 3 B 3.3.5-1 Amendment Nos. 300,300,&-30

ESPS Analog Instrumentation B 3.3.5 BASES BACKGROUND (continued)

LCO 3.3.5 covers only the analog instrumentation channels that measure these Parameters. These channels include all intervening equipment necessary to produce actuation before the measured process Parameter exceeds the limits assumed by the accident analysis. This includes sensors, bistable devices, operational bypass circuitry, and output relays.

LCO 3.3.6, "Engineered Safeguards Protective System (ESPS) Manual Initiation," and LCO 3.3.7, "Engineered Safeguards Protective System (ESPS) Digital Automatic Actuation Logic Channels," provide requirements on the manual initiation and digital automatic actuation logic Functions.

The ESPS contains three analog channels. Each analog channel provides input to digital logic channels that initiate equipment with a two-out-of-three logic on each digital logic channel. Each analog channel includes inputs from one analog instrumentation channel of Low RCS Pressure, Low Low RCS Pressure, High RB Pressure, and High High RB Pressure. Digital automatic actuation logic channels combine the three analog channel trips to actuate the individual Engineered Safeguards (ES) components needed to initiate each ES System. Figure 7.5, UFSAR, Chapter 7 (Ref. 1),

illustrates how analog instrumentation channel trips combine to cause digital logic channel trips.

The following matrix identifies the analog instrumentation (measurement) channels and the Digital Automatic Actuation Logic Channels actuated by each.

The ES equipment is generally divided between the two redundant digital actuation logic channels. The division of the equipment between the two digital actuation logic channels is based on the equipment redundancy and OCONEE UNITS 1, 2, & 3 B 3.3.5-2 Amendment Nos. 300, 300, & 30

ESPS Analog Instrumentation B 3.3.5 BASES APPLICABLE Reactor Building Spray. Reactor Building Cooling, and SAFETY ANALYSES Reactor Building Isolation (continued)

The ESPS actuation of the RB coolers and RB Spray have been credited in RB analysis for LOCAs, both for RB performance and equipment environmental qualification pressure and temperature envelope definition.

Accident dose tclcoaations nsave eB R solation-an R

Penetration-Room-Ventilation-Actuationi

-The-ESPS-aGtuation-f-the-penetration-roem-ventilation-system-has-been-assumed-for-OAsAccdent-dose-calculations-have-Gredited

-penetrationr-om-ventilationf-K eowee-HtaibneFwntaF The ESPS initiated Keowee Hydro Unit Emergency Start has been included in the design to ensure that emergency power is available throughout the limiting LOCA scenarios.

The small break LOCA analyses assume a conservative 48 second delay time for the actuation of HPI and LPI in UFSAR, Chapter 15 (Ref. 4). The large break LOCA analyses assume LPI flow starts in 38 seconds while full LPI flow does not occur until 15 seconds later, or 53 seconds total (Ref. 4). This delay time includes allowances for Keowee Hydro Unit starting, Emergency Core Cooling Systems (ECCS) pump starts, and valve openings. Similarly, the RB Cooling, RB Isolation, and RB Spray have been analyzed with delays appropriate for the entire system analyzed.

Accident analyses rely on automatic ESPS actuation for protection of the core temperature and containment pressure limits and for limiting off site dose levels following an accident. These include LOCA, and MSLB events that result in RCS inventory reduction or severe loss of RCS cooling.

The ESPS channels satisfy Criterion 3 of 10 CFR 50.36 (Ref. 5).

LCO The LCO requires three analog channels of ESPS instrumentation for each Parameter in Table 3.3.5-1 to be OPERABLE in each ESPS digital automatic actuation logic channel. Failure of any instrument renders the affected analog channel(s) inoperable and reduces the reliability of the affected Functions.

OCONEE UNITS 1, 2, & 3 B 3.3.5-6 BlI

ESPS Manual Initiation B 3.3.6 BASES APPLICABLE The ESPS manual initiation ensures that the control room operator can SAFETY ANALYSES rapidly initiate ES Functions. The manual initiation trip Function is required (continued) as a backup to automatic trip functions and allows operators to initiate ESPS whenever any parameter is rapidly trending toward its trip setpoint.

The ESPS manual initiation functions satisfy Criterion 3 of 10 CFR 50.36 (Ref. 1).

LCO Two ESPS manual initiation channels of each ESPS Function shall be OPERABLE whenever conditions exist that could require ES protection of the reactor or RB. Two OPERABLE channels ensure that no single random failure will prevent system level manual initiation of any ESPS Function. The ESPS manual initiation Function allows the operator to initiate protective action prior to automatic initiation or in the event the automatic initiation does not occur.

The required Function is provided by two associated channels as indicated in the following table:

Function Associated Channels HPI and RB Non-Essential 1 & 2 Isolation, Keowee Emergency Start, Load Shed and Standby Breaker Input, and Keowee Standby Bus Feeder Breaker Input LPI 3&4 RB Cooling1B Essential isolation, 5&6 aneration -Roomtent RB Spray 7&8 APPLICABILITY The ESPS manual initiation Functions shall be OPERABLE in MODES 1 and 2, and in MODES 3 and 4 when the associated engineered safeguard equipment is required to be OPERABLE. The manual initiation channels are required because ES Functions are designed to provide protection in these MODES. ESPS initiates systems that are either reconfigured for decay heat removal operation or disabled while in MODES 5 and 6.

Accidents in these MODES are slow to develop and would be mitigated by manual operation of individual components. Adequate time is available to evaluate unit conditions and to respond by manually operating the ES components, if required.

I OCONEE UNITS 1, 2, & 3 B 3.3.6-2 Amendment Nos. 328, 328 & 329 l

ESPS Automatic Digital Actuation Logic Channels B 3.3.7 BASES BACKGROUND (continued) includes allowances for Keowee Hydro Unit startup and loading, ECCS pump starts, and valve openings. Similarly, the reactor building (RB)

Cooling, RB Isolation, and RB Spray have been analyzed with delays appropriate for the entire system.

The ESPS automatic initiation of Engineered Safeguards (ES) Functions to mitigate accident conditions is assumed in the accident analysis and is required to ensure that consequences of analyzed events do not exceed the accident analysis predictions. Automatically actuated features include HPI, LPI, RB Cooling, RB Spray, and RB Isolation.

APPLICABLE Accident analyses rely on automatic ESPS actuation for protection of the SAFETY ANALYSES core and RB and for limiting off site dose levels following an accident. The digital automatic actuation logic is an integral part of the ESPS.

The ESPS digital automatic actuation logic channels satisfy Criterion 3 of 10 CFR 50.36 (Ref. 3).

LCO The digital automatic actuation logic channels are required to be OPERABLE whenever conditions exist that could require ES protection of the reactor or the RB. This ensures automatic initiation of the ES required to mitigate the consequences of accidents.

The required Function is provided by two associated digital channels as indicated in the following table:

Function Associated Channels HPI and RB Non-Essential 1 & 2 Isolation, Keowee Emergency Start, Load Shed and Standby Breaker Input, and Keowee and s

eeerBreket~nput LPI and R9 Essential isolation 3 i4 RB CoolingvB Essential isolationx5

/

~~RB Spray 7 & 8 V~ ~~~n znt~inRo '.'on

\\

O

/~~~~~~~~&

OCONEE UNITS 1, 2, & 3 B 3.3.7-2 Amendments

°(

XX

toht ULseCt

-RV'S-B 3.7.1 0 B 3.7 PLANT SYSTEMS B 3.7.10 Ucnetia1;lic,,

fl3ui

'v'.Ii<lc1uI 3ydem R

)

Jc Lco ASES OUND The PRVS filters air from the area of the active penetration rooms during the recirculation phase of a loss of coolant accident (LOCA).

The PRVS consists of two independent, redundant trains. Each train

\\

consists of a profie a high efficiency particulate air (HEPA) filter, an

\\activate on ads rber section for removal of gaseous activity yprincipally"i dines), nd a fan. Ductwork, valves or dampers, and in'stsrumentatio for part of the system. The system initiates filtered ventilation of the Re r

ilding penetration rooms area following receip'tof an Engi eere \\Safeguards actuation signal (ESAS).

The PRVSMs a stand jnsteDuring emergency operations, the PRVS valvei re realign and fans are started to begin filtration. Upon receipt of the AS signat, the sum of ventilation air discharges through the syst filter trai Is.

prtiiters remove any large particles in the air, and any &ntrained wa't drbplets p esent, to prevent excessive loading of the HEPA ters and caron adsorb rs.

The PRVS is discussed ine UFSAR

.1, 9.4.7, and 15.4.7 (Refs. 1, 2, and 3, respecti I)<

APPLICABLE SAFETY ANALYSES The design basis of the PRVS is es blishedib\\y the Maximum Hypothetical Accident (MHA). In such a case, the system limits radioactive releases to within 10 CFR 1 (Ref. 7) requirements and personnel doses in the Control Room are aintained within the limits of 10 CFR 20 (Ref. 4). The analysis of the eff ts and consequences of an MHA is presented in Reference 3.

The PRVS also actuates following a large and sm break LOCA, in those cases where the unit goes into the recirculatio ode of long term cooling, and to cleanup releases of smaller leaks, such s from valve stem packing.

Following a LOCA, an ESAS starts the PRVS fans and opens e

dampers located in the penetration room outlet ductwork.

The PRVS satisfies Criterion 3 of 10 CFR 50.36 (Ref. 5).

OCONEE UNITS 1, 2, & 3 B 3.7.1 0-1 BASEG RlE'WSICN DATfED 74816/1 I C"A4-I~Xlots.

XW50Cj Y

PRVS B 3.7.1 0

\\NCASES (continued)

LC Two independent and redundant trains of the PRVS are required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other train coincident with loss of offsite power.

The PRVS is considered OPERABLE when the individual components necessary to maintain the penetration room filtration are OPERABLE in both trains.

A PRVS trai cons ered OPERABLE when its associated:

a\\8 tFan is OPE BLE;

b.

HEPt and rbon adsorber are not excessively restricting flow, and a apa of performing their filtration functions; and

c.

D

twork, alves, and mpers are OPERABLE, and air flow can be aintained.

In addition, th enetra in room boundaries, including the integrity of the walls, floors, ceiigs, du twork, a a cess doors, must be maintained within the assumionns of thed analysis.

APPLICABILITY In MODES 1, 2, 3, an 4, the\\aVS is requ d to be OPERABLE consistent with the OP ABILITY require s of the containment.

In MODES 5 and 6, the PqVS is not quired to OPERABLE since the containment is not required be ERAB k

ACTIONS A.1 With one PRVS train inoperable, a ion m'ust be taken to restore the PRVS train to OPERABLE status wit in 7 days. During this time, the remaining OPERABLE train is adequae to perform the PRVS safety function. However, the overall reliabili s reduced because a single failure in the OPERABLE PRVS train cou result in loss of PRVS function.

The 7 day Completion Time is appropriate be use the risk contribution is less than that of the ECCS (72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completin Time), and this system is not a direct support system for the ECCS. Th 7 day Completion Time is based on the low probability of an accident occu ing during this time period, and ability of the remaining train to provide treuired capability.

OCONEE UNITS 1, 2, & 3 B 3.7.1 0-2 BASES REVISION DFA D 07/18/01 l

PRVS

\\~~~~~~~~~~~~~~~~~~~~~~~~~

B3.7.1 0 ABSES ACTIS B.1 and B.2 (continud If the required Action and associated Completion Time are not met, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion imes are reasonable, based on operating experience, to reach the r

uired unit conditions from full power conditions in an orderly manner an ttout challenging !A it systems.

SURVEILLANCE SR 3.7.@

REQUIREMENTS\\

Standby yt~

ol checked periodically to ensure that they function properi Size environ nt and normal operating conditions on this stem are sevlre, testing each train once a month provides an adequa ch onis synem. The 31 day Frequency is based on known relia lityf equipment and the two train redundancy available.

SR 3.7.10.2 This SR verifies that the require)

R eerformed in accordance with the Ventilation Fil r T ting PrograM (VFTP). The VFTP includes testing HEPA filter p or nce and e;on adsorber efficiency. Specific test frequencies a d additioainformxion are discussed in detail in the VFTP.

SR 3.7.10.3 This SR verifies the.t each PRVS train starts an operates on an actual or simulated actuation signal. The 18 month Frequ ncy is consistent with the guidance in Reference 6.

SR 3.7.10.4 This SR verifies the integrity of the penetration rooms area The ability of the PRVS to maintain a negative pressure, with respect to outside atmosphere, is periodically tested to verify proper functioning f the PRVS. During the post accident mode of operation, the PRVS OCONEE UNITS 1, 2, & 3 B 3.7.10-3 BASES REVISION DATED 07/18/01

PRVS

\\~~~~~~~~~~~~~~~~~~~~~~~~~

B3.7.1 0 B ES SURVE LNCE SR 3.7.10.4 (continued)

REQUIRE ENTS designed to maintain a slight negative pressure in the penetration rooms with respect to outside atmosphere to prevent unfiltered LEAKAGE. The PRVS is designed to maintain this negative pressure at a flow rate of 1000 +/- 10% cfm from the area. The Frequency of 18 months on a TAGGERED TEST BASIS is consistent with industry practice and other figurion SRs.

Operatin system f valve is' with the pass valve is necessary to ensure that the he OPERABILITY of the PRVS filter bypass 9_g'd\\ An 18 month Frequency is consistent REFERENCES

1.

UFSAR, Sec

2.

UFSAR, Sectic

3.

UFSAR, Section 1

4.

10 CFR 20.

5.

10 CFR 50.36.

6.

Regulatory Guide 1.52.

7.

10 CFR 100.

BASES REVISION DATED 0 18/ 1 l OCONEE UNITS 1, 2, & 3 B 3.7.1 0-4

SFPVS B 3.7.17 B 3.7 PLANT SYSTEMS B 3.7.17 Spent Fuel Pool Ventilation System (SFPVS)

BASES BACKGROUND Ventilation air for the Spent Fuel Pool Area is supplied by an air handling unit which consists of roughing filters, steam heating coil, cooling coil supplied by low pressure service water, and a centrifugal fan. In the normal mode of operation, the air from the Spent Fuel Pool Area is exhausted directly to the unit vents by the general Auxiliary Building exhaust fans. The filtered exhaust system consists of a single filter train and two 100 percent capacity vane axial fans. The filter'train utilized is the Reactor Building Purge Filter Train. The Unit 2 Reactor Building purge filter train is used for the combined Unit I and 2 Spent Fuel Pool Ventilation System, The Unit 3 Reactor Building purge filter train is used Jor the Unit 3 SFP Ventilation System. The filter train is comprised of prefilters, HEPA filters, and charcoal filters. To control the direction of air flow, i.e., to direct the air from the Fuel Pool Area to the Reactor Building Purge Filter Train, a series of pneumatic motor operated dampers are provided along with a crossover duct from the Fuel Pool to the filter train.

The SFPVS is discussed in the UFSAR, Section 9.4.2, (Ref. 1).

APPLICABLE The analysis-of the limiting fuel handling accident, the cask drop SAFETY ANALYSES accident, given in Reference 2, assumes that a certain number of fuel assemblies are damaged. The DBA analysis for the cask drop accident, does not ime operation of the SFPVSThese assumptions and the an sire cc istent with the guidance Pi Gu 1.ES (Ref 3).

4t-Do

,,.4 8 3

/{

con~~~~~~~IC 0CfZ.60 b

d The SFPstis e

1 cr e i 10 Tk.

AtSFPS l's rdnad fin '1/; 5 pe"'

4 rAL4A Puxoes-LCO da trains of the SFPVS are required t e esure that at le o

efiueta di e

r train.

WL)L

~Lado ptA.

o/n fik a/kn a6Lor I, a X and 4kii,ns/vjIclao/71 oF vcu lws p/ant r1m4r sr-ev~S 15 1 credi+/-hd A ctca~

CNEE UIS,,3B3711At a,

no sp OCONEE UNITS 1, 2, & 3 3..71AedWn o~i0

SFPVS I B 3.7.17 BASES LCO (conti An SFPVS train is considered OPERABLE when its associated:

nued)

\\ 1.

Fan is OPERABLE;

/2.

iHEPA lter La= o b rae not excessively restricing

/

~~~flouw, arnd are capsh1o of performing thoir filtration funci~jand\\

3.

Ductwork and dampers are OPERABLE, and air flow can be maintained.

lrhc LCO is modified by4wo-NMotes Note 1 tacl 3

doos-nnf-ppyly ing4uoonductn ranee r

th

.Actlon~mvii§4 Ge-ondueoting-efane-GparationswihIor oe tl ore l

Di 1oDE 1, 2, 3, U1 4,the-fue~fnovementis-Jndependen t-ol raoration&Fherefore~inability4o-suspead-movement-of u9'la6semblies-s-not-a sufficient reasov o-equire-a

/eactorshutdown.-Note-2est sthe-requirements-efhis-L s-net-app~iable-duringeraeking-operatiok ith no fue-nthe-ent-fueFpoof--

With-ne-fuel-in-the spent fuelpoothe-lotetial-release lradwactjve ia!to thoenvirons resulting #rom-cranq-p is-witmhead erhq-

>C>>...toragc poo~l is subLai ~ltaIty-reduA

/

,ABILITY During movement ofifue the fu I tandling area er during-oary ne

.operations with

roa, the SFPVS S

s TetSired-te be OPERABLE.

-h°.lA APP ACTIONS

=

a

/

W~ith one SFPVS train inoperable, the OPERABLE SFV tra n m

(

started~

~

~~1 rmeitl r;.schaugh the associated reactor\\

/

~~building purge file prueit rr ovement in le spent fuel pool engi-efef

/pe~atkms-with loade over the cpent fuol poe1 suspended. This action ensures that the remaining train is OPERABLE, and that any active failures will be readily detected.

If the system is not placed in operation, this action requires suspension of rvcerdlf

-rya~jditi4fuel movement and surponcion of crane oper i

v which precludes a f.el ha dlinq gcjifin/ This action does not preclude the movement of ul ti'sto a

~~safe position.

OCONEE UNITS 1, 2, & 3 B 3.7.17-2 An enzjjw&71iJos. x Xx,( y,(

SFPVS B 3.7.17 BASES ACTIONS B.1 (continued)

When two trains of the SFPVS are ino erable during movement of fuel in the spystes s ee d

alyens Lfct potpely.A This Action involvas immediately suspe oovement of fuel assemblies in the spent fuel poonce e m

iades np ardein uith Invc e

systhe ntefmla..

Thistdoes t&_

Stnedbny heypsrteds should e he.asciaed-etobuligps fprlunetionproer.

fsov o ftel feovro 1ent t

an d e rating c th

~mton thi sythem ar~emnt severe, t~estngeahtinioyncbaed-on~ermown-As~~~~*

)2-~'LX./ ed~hgOassociate2.eae..Wsing puc ThisSR verifiesthatthe requirednSEPuVestingiford i REQUIRcodT e wittilo Fog VFTP.

T VtdeysystemstingoHEP bterheked ic, hroa dsre efficiency minimumy Asysthem flowrae, andtepyIca propetedoh aciaenhroa (generCoAalt ue and floing spcfcoeatin)

This specifictes are q nces ud adin ifr testing are discused in detail in the VFTP.

REFERENCES tFS9R~etI6i;

)n2.

UFSAR, Section 15.11.

a

/

1~~~~~~83

/ 3.

Regulatory Guide 1.as A-.~~~~~~~W L tlM'~t~-

IO43O.

07 5o.

o

/~~nr s;

Dos

=;I capons,7 l~~~~~~~~~~'

tinFle etfpor OCONEE UNITS 1, 2, & 3 B 3.7.17-3 Amendment Nos.

p r

f, &3h aciae chrol(eea s

n olwn pcfcoeain)

ATTACHMENT 3 TECHNICAL JUSTIFICATION

ATTACHMENT 3 TECHNICAL JUSTIFICATION BACKGROUND:

On October 16, 2001, the license amendment request (LAR) for approval of the Alternate Source Term (AST) analysis methodology for Oconee Nuclear Station (ONS) was submitted.

This license amendment will support simplification of Ventilation System testing requirements during core alterations or movement of irradiated fuel. Duke Energy Corporation (Duke) received additional questions from the NRC related to the AST submittal. Responses to these questions were submitted on May 20, 2002, September 12, 2002, November 21, 2002, January 27, 2003, and September 22, 2003.

Penetration Room Ventilation System (PRVS) and Spent Fuel Pool Ventilation System (SFPVS) were removed from ONS Technical Specifications (TS) in the original submittal.

In the submittal dated September 22, 2003, Duke committed to maintain relaxed requirements for PRVS and SFPVS in TS.

After additional conversations with the NRC, Duke will remove PRVS from TS and maintain SFPVS in TS.

Duke also intends to adopt TSTF-51 with respect to the SFPVS TS conditions, but relax certain surveillance requirement (SR) criteria associated with running the SFPVS trains.

JUSTIFICATION FOR REQUEST:

The submitted dose analysis does not credit removal of radiological contaminants by the PRVS subsequent to a Loss Of Coolant Accident (LOCA) or Fuel Handling Accident (FHA) inside containment, or by the SFPVS in the spent fuel pool building.

Because the analysis no longer credit PRVS and SFPVS, they no longer meet the criterion for inclusion in TS as defined in 10 CFR 50.36.

Duke will remove the PRVS from TS, but retain and relax certain surveillance requirements for SFPVS TS.

Retaining the TS for SFPVS is for ALARA purposes.

In the submittal dated September 22, 2003, Duke had partially adopted TSTF-51 and the language associated with recently irradiated fuel assemblies for the SFPVS TS.

TSTF-51 will be adopted fully with the exception of the relaxed SR.

Justification for TSTF-51 can be referenced in that submittal.

I

Because the analysis no longer credit SFPVS, the SR can be relaxed as long as the fans are proven OPERABLE prior to moving recently irradiated fuel.

Description of Changes:

Technical Specification (TS) 3.3.6, Engineered Safeguards Protective System (ESPS) Manual Initiation The ESPS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and mitigate accidents.

PRVS is one of the systems actuated by the ESPS.

Since the PRVS will not be credited for Control Room and off-site doses based on the revised radiological analyses of the MHA, the PRVS is being removed as an ESPS function from TS 3.3.6 TS 3.7.10, Penetration Room Ventilation System (PRVS)

PRVS and its associated TS Bases will be removed from TS.

The PRVS will not be credited for evaluating potential Control Room and off-site doses.

This change results in an operational efficiency that is achievable from implementing the AST.

The revised radiological analysis of the MHA are performed without taking credit for the PRVS filter system and the results of this analysis show that the offsite and Control Room doses remain below the Regulatory Guide 1.183 limits.

Removal of this system from TS eliminates the requirement to demonstrate the effectiveness of this system in operation.

This simplifies testing design and performance tasks.

TS 3.7.17, Spent Fuel Pool Ventilation System (SFPVS)

The NOTES are being deleted from the LCO.

The APPLICABILITY of TS 3.7.17 is being revised to include movement of 'recently irradiated fuel assemblies' in the spent fuel pools.

The APPLICABILILITY of 'During crane operations with loads over the spent fuel pool' is being deleted.

Required Actions A.2.1 and B.1.1 are being revised to include 'recently irradiated fuel assemblies.'

2

The logical connectors AND for REQUIRED ACTIONS A.2.2 and B.1.2, REQUIRED ACTION (RA) A.2.2, RA B.1.2 and their associated COMPLETION TIMES are being deleted.

The Completion Time for SR 3.7.17.1 is being revised from 31 days to 31 days prior to movement of recently irradiated fuel assemblies AND 6 months.

TS 5.5, Programs and Manuals TS 5.5.2, Containment Leakage Rate Testing Program Part b of the leakage rate acceptance criteria will be deleted as a result of removing PRVS from the TS.

TS 5.5.12, Ventilation Filter Testing Program (VFTP)

References to PRVS will be removed from the VFTP.

PRVS Tests a, c, and f will be deleted.

The tests will be relettered.

TS 5.6, Reporting Requirements TS 5.6.6, Post Accident Monitoring (PAM) and Main Feeder Bus Monitor Panel (MFPMP) Report The changes to TS 5.6.6, Post Accident Monitoring (PAM) and Main Feeder Bus Monitor Panel (MFPMP) Report, reflected in the submittal dated September 22, 2003, are no longer applicable.

These pages are removed from the submittal.

TS Bases (TSB) 3.3.5, ESPS Analog Instrumentation This section is affected by the removal of the PRVS from the ESPS and is being revised to remove all references to PRVS.

TSB 3.3.6, ESPS Manual Initiation This section is affected by the removal of the PRVS from the ESPS and is being revised to remove all references to PRVS.

3

TSB 3.3.7, ESPS Automatic Digital Actuation Logic Channels This section is affected by the removal of the PRVS from the ESPS and is being revised to remove all references to PRVS.

TSB 3.7.10, PRVS The bases for TS 3.7.10 is being removed from the TS.

TSB 3.7.17, SFPVS A statement is being added to the 'APPLICABLE SAFETY ANALYSIS' regarding retaining the SFPVS TS because of ALARA purposes.

The 'LCO' is being revised to delete the NOTES in their entirety.

The 'APPLICABILITY' is being revised to reference 'recently irradiated fuel assemblies.'

Action A.1 and A.2 will be revised to delete reference to crane operations with loads over the spent fuel pool.

Action B.1 will be revised to reflect to delete reference to crane operations with loads over the spent fuel pool.

The Completion Time for SR 3.7.17.1 was revised from 31 days to 31 days prior to movement of recently irradiated fuel AND 6 months.

This will ensure the system is OPERABLE prior to movement of recently irradiated fuel.

Since, the system is no longer credited in dose analysis calculations and is not required to maintain 10 CFR 50.67 dose limits, a relaxed testing frequency of 6 months is acceptable.

In the reference section, Regulatory Guide 1.25 will be revised to 1.183.

10 CFR 50.67 and Dose Calculations will be added to the reference section.

4

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION

ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS Standards for determining whether a license amendment involves no significant hazards considerations are contained in 10CFR50.92(c).

The TS changes and modifications as proposed in this LAR have been evaluated in accordance with 10 CFR 50.92 and determined not to involve any significant hazards considerations.

The proposed LAR includes (1) implementing the AST for accident analysis as described in Regulatory Guide 1.183; (2) removing the PRVS and relaxing the SFPVS TS because they are no longer credited for Control Room and off-site doses; (3) revising the CRVS to allow for a one time completion time extension on Conditions B and C when entering the conditions to support implementation of the Control Room intake/booster fan modification; (4) lowering the Reactor Building leakage rate from 0.25 w%/day to 0.20 w%/day; (5) revising the VFTP radioactive methyl iodide removal acceptance criterion for SFPVS and CRVS Booster Fan trains; and (6) adoption of TSTF-51.

Plant modifications are also being proposed in concert with the proposed TS changes.

They include relocating the existing Control Room outside air intake from the roof of the.'Auxiliary Building to the roof of the Turbine Building and installing dual intakes for each Control Room; re-routing HPI/LPI relief valve discharge back into the Reactor Building and replacing the existing Caustic Addition system with a passive system.

As a result of this evaluation, Duke has concluded:

1) The proposed amendment will not involve a significant increase in the probability of consequences of an accident previously evaluated.

The AST and those plant systems affected by implementing the proposed changes to the TS are not assumed to initiate design basis accidents.

The AST does not affect the design or operations of the facility.

Rather, the AST is used to evaluate the consequences of a postulated accident.

The implementation of the AST has been evaluated in the revisions to the analysis of the design basis accidents for ONS.

Based on the results of these

i J, ' I ' " I '-, I,

':V , 1 %!,.,, - I analyses, it has been demonstrated that, with the requested changes, the dose consequences of these events meet the acceptance criteria of 10 CFR 50.67 and Regulatory,Guide 1.183.

Therefore, the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The AST and those plant systems affected by implementing the proposed changes to the TS are not assumed to initiate design basis accidents.

The systems affected by the changes are used to mitigate the consequences of an accident that has already occurred.

The proposed TS changes and modifications do not significantly affect the mitigative function of these systems.

Consequently, these systems do not alter the nature of events postulated in the Safety Analysis Report nor do they introduce any unique precursor mechanisms.

Therefore, the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed amendment will not involve a significant reduction in the margin of safety.

The implementation of the AST, proposed changes to the TS and the implementation of the proposed modifications have been evaluated in the revisions to the analysis of the consequences of the design basis accidents for the ONS.

Based on the results of these analyses, it has been demonstrated that with the requested changes the dose consequences of these events meet the acceptance criteria of 10 CFR 50.67 following the provisions of Regulatory Guide 1.183.

Thus, the proposed amendment will not involve a significant reduction in the margin of safety.

ML033370889

Text

Subject:

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