ML042030312

Supplement 7 to the License Amendment Request (LAR) for Temporary Extension to the Completion Times for One and Two Keowee Hydro Units Inoperable Technical Specification Change (TSC) Number 2002-05

ML042030312
Person / Time
Site:	Oconee
Issue date:	07/12/2004
From:	Barron H Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML042030312 (49)

Text

Duke HENRY B. BARRON

• rPowere Group VP, Nuclear Generation and A Duke Energy Company Chief Nuclear Officer Duke Power EC07H / 526 South Church Street Charlotte, NC 28202-1802 Mailing Address:

PO Box 1006 EC07H Charlotte, NC 28201-1006 704 382 2200 July 12, 2004 743220 704 382 6056 fax hbarron@duke-energy.com 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 7 to the License Amendment Request (LAR) for Temporary Extension to the Completion Times for One and Two Keowee Hydro Units Inoperable Technical Specification Change (TSC) Number 2002-05 In a submittal dated August 22, 2002, and supplemented by letters dated September 12, 2003, and February 4, February 16, March 23, April 28, and June 17, 2004, Duke proposed to amend Appendix A, Technical Specifications, for Facility Operating Licenses DPR-38, DPR-47 and DPR-55 for Oconee Nuclear Station, Units 1, 2, and 3. The amendment would temporarily extend Technical Specification (TS) 3.8.1 Required Action Completion Times when in the Conditions for one or two Keowee Hydro Units (KHU) inoperable to allow significant maintenance and upgrades to be performed.

Since the June 17, 2004, Supplement, Duke identified a necessary revision to make the proposed TS change apply as intended. The revised proposed TS change is described in Attachment 1.

During a June 22, 2004, conference call between Duke and NRC, Duke agreed to notify the NRC via the Emergency Notification System (ENS) should grid or weather related criteria be met that requires Duke to evaluate the need to exit the dual KHU outage.

During a June 25, 2004, telephone call between Duke and NRC, Duke agreed to provide an additional contingency www. dukepower. corn

U. S. Nuclear Regulatory Commission July 12, 2004 Page 2 measure to address the unlikely scenario where all offsite power (Switchyard, Jocassee, and Lee Combustion Turbines) and the Standby Shutdown Facility (SSF) becomes unavailable during the dual KHU outages. Duke will provide backup power capability for the Turbine Driven Emergency Feedwater Pump (TDEFWP) controls and valves to allow the pumps to continue feeding the Steam Generators on each Oconee Unit beyond the station battery life until a KHU can be restored. Portable generators will be staged for the TDEFWPs along with the necessary equipment/cables and appropriate guidance for connection should the unlikely scenario described above occur. and 3 provide revised TS retyped pages and markup pages that reflect the changes proposed in . For completeness Attachment 2 and 3 also include all the changes associated with the LAR. provides a revised list of NRC commitments.

The additional proposed changes do not affect the conclusions of the No Significant Hazards Consideration included in the August 22, 2002 LAR.

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 Boyd Shingleton at (864) 885-4716.

Very truly yours,

/A? K Henry B. Barron Group Vice President, Nuclear Generation, and Chief Nuclear Officer Duke Energy Corporation

U. S. Nuclear Regulatory Commission July 12, 2004 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. W. D. Travers, 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 July 12, 2004 Page 4 Oath and Affirmation I affirm that I, Henry B. Barron, am the person who subscribed my name to the foregoing, and that all the matters and facts set forth herein are true and correct to the best of my knowledge.

Henry B. Barron Subsc 'bed and sworn to before me this / day of 2004.

7 A~ublI"~

My Commission Expires:

', -Loo Date Id, July 12, 2004 Page 1 Attachment 1 Revision to Proposed Change to the Technical Specifications In a submittal dated August 22, 2002, and supplemented by letters dated September 12, 2003, and February 4, February 16, March 23, April 28, and June 17, 2004, Duke proposed extending the Completion Time (CT) for restoring one Keowee Hydro Unit (KHU) to operable status when two are inoperable. Duke also proposed extending the 45 day CT of Required Action (RA) C.2.2.5 for restoring a KHU associated with the overhead emergency power path by 17 days and the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CTs of RA D.3 for restoring a KHU associated with the underground emergency power path.

Since submittal of the last supplement, Duke identified a non technical problem that would preclude using the 45 day CT of Technical Specification (TS) 3.8.1 RA C.2.2.5 when in Condition H greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It would also preclude entering Condition H again when the Oconee Units have been in Condition C for > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (45 day CT of TS 3.8.1 RA C.2.2.5 in effect). Currently, TS 3.8.1, RA C.2.2.3 requires verifying administratively that the remaining KHU and its required underground power path are OPERABLE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as a condition for using the 45 day CT of RA C.2.2.5. RA C.2.2.4 requires verification of alternate power source capability by performing Surveillance Requirement (SR)-3.8.1.16 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as another condition for using the 45 day CT. SR 3.8.1.16 is an administrative verification that the KHU associated with the underground emergency power path can be automatically or manually aligned to the overhead emergency power path. RA C.2.2.3 also requires verifying that Limiting Condition for Operation (LCO) 3.3.21 is met prior to exceeding the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT. LCO 3.3.21 requires the Keowee Emergency Start Function be OPERABLE. While this requirement can be met, there is no reason for the requirement when also in Condition H since neither KHU would be available to automatically start. Since these aspects of RA C.2.2.3 and RA C.2.2.4 can not be performed or met after exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> while in Condition H, Condition L would apply. Condition L requires compliance with RA C.2.2.3 and C.2.2.4 be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or entry into Condition M (shutdown requirement).

This LAR supplement proposes to add a Note indicating that RA C.2.2.3 is not applicable to the remaining KHU and its required underground emergency power path or LCO 3.3.21 when in Condition H to perform Keowee Refurbishment Upgrades. The KHU associated with the underground emergency power path is not OPERABLE while in Condition H; therefore, administrative verification of OPERABILITY is not possible.

OPERABILITY of that KHU will be demonstrated prior to returning to service. When in Condition H there is no need to verify LCO 3.3.21 is met since the function serves no purpose when both KHUs are inoperable. The proposed change also adds a Note to RA

Attachment 1 July 12,2004 Page 2 C.2.2.4 indicating that it is not applicable when in Condition H to perform Keowee Refurbishment Upgrades since the KHU associated with the underground emergency power path is not OPERABLE while in Condition H. The alternate power source capability will be verified after returning a KHU to service. These proposed changes allow the 45 day CT of RA C.2.2.5 to be used while in Condition H to perform Keowee Refurbishment Upgrades and makes the proposed change apply as intended. The justification provided in the initial submittal and subsequent supplements are applicable to this proposed change. As such, no further justification is provided.

Attachments 2 and 3 provide the revised TS pages and markup pages that reflect the change described above.

July 12, 2004 ATTACHMENT 2 TECHNICAL SPECIFICATION Remove Page Insert Page 3.8.1 8 3.8.1 8 B 3.8.1 25 B 3.8.1 26

AC Sources - Operating 3.8.1 ACTIONS CONDITION R REQUIRED ACTION COMPLETION TIME C. (continued) C.2.2.3 ---- NOTE-------------

Not applicable to remaining KHU and its required underground emergency power path or LCO 3.3.21 when in Condition H to perform Keowee Refurbishment Upgrades.

Verify by administrative 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> means that the remaining KHU and its required underground emergency power path and both required offsite sources are OPERABLE and the requirements of LCO 3.8.3, "DC Sources-Operating," LCO 3.8.6,

'Vital Inverters-Operating," LCO 3.8.8, "Distribution Systems-Operating," LCO 3.3.17, "EPSL Automatic Transfer Function," LCO 3.3.18, "EPSL Voltage Sensing Circuits," LCO 3.3.19, "EPSL 230 kV Switchyard DGVP,"

and LCO 3.3.21,

'EPSL Keowee Emergency Start Function" are met.

AND (continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -4 Amendment Nos. 300, 300, & 300

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION J REQUIRED ACTION J COMPLETION TIME C. (continued) C.2.2.4 -------- NOTE-------------

Not applicable when in Condition H to perform Keowee Refurbishment Upgrades.

Verify alternate power 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> source capability by performing AND SR 3.8.1.1 6.

Every 31 days thereafter AND C.2.2.5 Restore KHU and its 28 days when Condition required overhead due to an inoperable emergency power path Keowee main step-up to OPERABLE status. transformer AND

---

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

An additional 17 days is allowed when Condition entered to perform KHU Refurbishment Upgrades prior to April 30, 2005 except during March, April, May or June 45 days from discovery of initial inoperability when Condition due to an inoperable KHU if not used for that KHU in the previous 3 years (continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -5 Amendment Nos. I

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION I REQUIRED ACTION I COMPLETION TIME D. KHU or its required D.1 Perform SR 3.8.1.4 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if not performed underground power OPERABLE KHU. in previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> path inoperable.

AND D.2 Energize either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> standby bus from LCT via isolated power AND path.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from subsequent discovery of deenergized required standby bus AND D.3 Restore KHU and its ------------NOTE-----------

required underground The extended emergency power path Completion Time of to OPERABLE status. Required Action H.2 is applicable in lieu of these Completion Times when in Condition H to isolate, test and unisolate the KHUs during each of the two KHU Refurbishment Outages.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from discovery of inoperable KHU OCONEE UNITS 1,2, &3 3.8.1 -6 Amendment Nos. I

AC Sources - Operating 3.8.1 ACTiONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for one unit associated Completion Time not met for AND Required Action D.2.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for other unit(s)

AND E.2 Be in MODE 5. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> F. Zone overlap protection F.1 Restore zone overlap 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuitry inoperable protection circuitry to when overhead OPERABLE status.

electrical disconnects for KHU associated OR with the underground power path are closed. F.2 Open overhead 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> electrical disconnects for KHU associated with the underground power path.

G. Both emergency power G.1 Restore one breaker to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> paths inoperable due to OPERABLE status.

one inoperable E breaker and one inoperable S breaker on the same main feeder bus.

(continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -7 Amendment Nos.

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION J REQUIRED ACTION J COMPLETION TIME H. -----------NOTE----------- H.1 Energize both standby 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of Condition may be buses from LCT via deenergized standby bus entered only when both isolated power path.

required offsite sources are verified by administrative means to AND be OPERABLE and the requirements of LCO H.2 Restore one KHU and ------------NOTE-----------

3.8.3, "DC its required emergency An additional cumulative Sources-Operating;" power path to 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> is allowed when LCO 3.8.6, "Vital OPERABLE status. Condition entered to isolate, Inverters-Operating;" test and un-isolate the LCO 3.8.8, "Distribution KHUs during each of the Systems-Operating;" two KHU Refurbishment LCO 3.3.17, NEPSL Outages prior to April 30, Automatic Transfer 2005 provided the following Function;" LCO 3.3.18, conditions are met: 1) period

'EPSL Voltage Sensing of use not in March, April, Circuits;" LCO 3.3.19, May or June; 2) the SSF, SEPSL 230 kV EFW System and LCTs are Switchyard DGVP," are verified OPERABLE prior to verified by entering Condition, 3) RCS administrative means to inventory is not reduced, 4) be met. the SSF is manned, 5) a Jocassee Hydro Unit is verified available to provide Both KHUs or their power prior to entering required emergency Condition, 6) a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> SSF power paths inoperable DG operability test is for planned performed prior to the start maintenance or test of the first dual unit outage, with both standby and 7) the Completion Time buses energized from is only extended twice LCT via isolated power during each KHU path. Refurbishment Outage.

60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> (continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -8 Amendment Nos. I

AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The AC Power System consists of the offsite power sources (preferred power) and the onsite standby power sources, Keowee Hydro Units (KHU). This system is designed to supply the required Engineered Safeguards (ES) loads of one unit and safe shutdown loads of the other two units and is so arranged that no single failure can disable enough loads to jeopardize plant safety. The design of the AC Power System provides independence and redundancy to ensure an available source of power to the ES systems (Ref. 1). The KHU turbine generators are powered through a common penstock by water taken from Lake Keowee.

The use of a common penstock is justified on the basis of past hydro plant experience of the licensee (since 1919) which indicates that the cumulative need to dewater the penstock can be expected to be limited to about one day a year, principally for inspection, plus perhaps four days every tenth year.

The preferred power source is provided from offsite power to the red or yellow bus in the 230 kV switchyard to the units startup transformer and the E breakers. The 230 kV switchyard is electrically connected to the 525 kV switchyard via the autobank transformer. Emergency power is provided using two emergency power paths, an overhead path and an underground path. The underground emergency power path is from one KHU through the underground feeder circuit, transformer CT-4, the CT-4 incoming breakers (SK breakers), standby bus and the standby breakers (S breakers). The standby buses may also receive offsite power from the 100 kV transmission system through transformer CT-5 and the CT-5 incoming breakers (SL breakers). The overhead emergency power path is from the other KHU through the startup transformer and the startup incoming breakers (E breakers). In addition to supplying emergency power for Oconee, the KHUs provide peaking power to the generation system. During periods of commercial power generation, the KHUs are operated within the acceptable region of the KHU operating restrictions.

This ensures that the KHUs are able to perform their emergency power functions from an initial condition of commercial power generation. The KHU operating restrictions for commercial power generation are contained in UFSAR Chapter 16, (Ref. 2). The standby buses can also OCONEE UNITS 1, 2, & 3 B 3.8.1 -1 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES BACKGROUND receive power from a combustion turbine generator at the Lee Steam (continued) Station through a dedicated 100 kV transmission line, transformer CT-5, and both SL breakers. The 100 kV transmission line can be supplied from a Lee combustion turbine (LCT) and electrically separated from the system grid and offsite loads. The minimum capacity available from any of the multiple sources of AC power is 22.4MVA (limited by CT-4 and CT-5 transformer capacities).

APPLICABLE The initial conditions of design basis transient and accident analyses SAFETY ANALYSIS in the UFSAR Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5) assume ES systems are OPERABLE. The AC power system is designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ES systems so that the fuel, reactor coolant system, and containment design limits are not exceeded.

Consistent with the accident analysis assumptions of a loss of offsite power (LOOP) and a single failure of one onsite emergency power path, two onsite emergency power sources are required to be OPERABLE.

AC Sources - Operating are part of the primary success path and function to mitigate an accident or transient that presents a challenge to the integrity of a fission product barrier. As such, AC Sources -

Operating satisfies the requirements of Criterion 3 of 10 CFR 50.36 (Ref. 3). L LCO Two sources on separate towers connected to the 230 kV switchyard to a unit startup transformer and one main feeder bus are required to be OPERABLE. Two KHUs with one capable of automatically providing power through the underground emergency power path to both main feeder buses and the other capable of automatically providing power through the overhead emergency power path to both main feeder buses are required to be OPERABLE. The Keowee Reservoir level is required to be > 775 feet above sea level to support OPERABILITY of the KHUs.

The zone overlap protection circuitry is required to be OPERABLE when the overhead electrical disconnects for the KHU associated with the underground power path are closed to provide single failure protection for the KHUs. The zone overlap protection circuitry includes the step-up transformer lockout, the underground KHU lockout, the Keowee emergency start signal, and the underground breaker for the overhead KHU to ensure the zone overlap protection circuitry logic is OPERABLE.

OCONEE UNITS 1, 2, & 3 B 3.8.1 -2 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES LCO Operable offsite sources are required to be "physically independent" (continued) (separate towers) prior to entering the 230 kV switchyard. Once the 230 kV lines enter the switchyard, an electrical pathway must exist through OPERABLE power circuit breakers (PCBs) and disconnects such that both sources are available to energize the Unit's startup transformer either automatically or with operator action. Once within the boundary of the switchyard, the electrical pathway may be the same for both independent offsite sources. In addition, at least one E breaker must be available to automatically supply power to a main feeder bus from the energized startup transformer. The voltage provided to the startup transformer by the two independent offsite sources must be sufficient to ensure ES equipment will operate. Two of the following offsite sources are required:

1) Jocassee (from Jocassee) Black or White,

2) Dacus (from North Greenville) Black or White,

3) Oconee (from Central) Black or White,

4) Calhoun (from Central) Black or White,

5) Autobank transformer fed from either the Asbury (from Newport), Norcross (from Georgia Power), or Katoma (from Jocassee) 525 kV line.

An OPERABLE KHU and its required emergency power path are required to be able to provide sufficient power within specified limits of voltage and frequency within 23 seconds after an emergency start initiate signal and includes its required emergency power path, required instrumentation, controls, auxiliary and DC power, cooling and seal water, lubrication and other auxiliary equipment necessary to perform its safety function. Two emergency power paths are available. One emergency power path consists of an underground circuit while the other emergency power pathway uses an overhead circuit through the 230 kV switchyard.

OCONEE UNITS 1, 2, & 3 B 3.8.1 -3 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES LCO An OPERABLE KHU and its required overhead emergency power path (continued) must be capable of automatically supplying power from the KHU through the KHU main step-up transformer, the 230 kV yellow bus, the Unit startup transformer and both E breakers to both main feeder buses. At least one channel of switchyard isolation (by actuation from degraded grid voltage protection) is required to be OPERABLE to isolate the 230 kV switchyard yellow bus. If closed, each N breaker must be capable of opening using either of its associated breaker trip circuits. Either of the following combinations provides an acceptable KHU and required overhead emergency power path:

Keowee Hvdro Unit Keowee Hvdro Unit 1A) Keowee Unit 1 generator, 1B) Keowee Unit 2 generator, 2A) Keowee ACB 1 (enabled by 2B) Keowee ACB 2 (enabled by one channel of Switchyard one channel of Switchyard Isolate Complete), Isolate Complete),

3A) Keowee auxiliary transformer 3B) Keowee auxiliary 1X, Keowee ACB 5, Keowee transformer 2X, Keowee Load Center 1X, ACB 6, Keowee Load Center 4A) Keowee MCC 1XA, 2X, 5A) Keowee Battery #1, Charger 4B) Keowee MCC 2XA,

1. 1 or Standby Charger, and 5B) Keowee Battery #2, Charger Distribution Center 1DA, #2 or Standby Charger, and 6A) ACB-1 to ACB-3 interlock, Distribution Center 2DA, S6B) ACB-2 to ACB-4 interlock,

7) Keowee reservoir level 2 775 feet above sea level, Overhead Emergency Power Path

8) . Keowee main step-up transformer,

9) PCB 9 (enabled by one channel of Switchyard Isolate Complete),

10) The 230kV switchyard yellow bus capable of being isolated by one channel of Switchyard Isolate,

11) A unit startup transformer and associated yellow bus PCB (CT-1 / PCB 18, CT-2 / PCB 27, CT-3 /

PCB 30),

12) Both E breakers.

OCONEE UNITS 1, 2, & 3 B 3.8.1-4 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES LCO An OPERABLE KHU and its required underground emergency (continued) power path must be capable of automatically supplying power from the KHU through the underground feeder, transformer CT-4, both standby buses, and both Unit S breakers to both main feeder buses. If closed, each N breaker and each SL breaker must be capable of opening using either of its associated breaker trip circuits. Either of the following combinations provides an acceptable KHU and required underground emergency power path:

Keowee Hydro Unit Keowee Hydro Unit 1A) Keowee Unit 1 generator, 1B) Keowee Unit 2 generator, 2A) Keowee ACB 3, 2B) Keowee ACB 4, 3A.1) Keowee auxiliary 3B.1) Keowee auxiliary transformer CX, Keowee transformer CX, Keowee ACB 7, Keowee Load ACB 8, Keowee Load Center 1X, Center 2X, 3A.2) One Oconee Unit 1 S 3B.2) One Oconee Unit 1 S breaker capable of breaker capable of feeding feeding switchgear 1TC, switchgear 1TC, 3A.3) Switchgear 1TC capable 3B.3) Switchgear 1TC capable of of feeding Keowee feeding Keowee auxiliary auxiliary transformer CX, transformer CX, 4A) Keowee MCC 1XA, 4B) Keowee MCC 2XA, 5A) Keowee Battery #1, 5B) Keowee Battery #2, Charger #1 or Standby *Charger #2 or Standby Charger, and Distribution Charger, and Distribution Center 1DA, Center 2DA, 6A) ACB-1 to ACB-3 interlock, 6A) ACB-2 to ACB-4 interlock,

7) Keowee reservoir level 2 775 feet above sea level, Underground Emergency Power Path

8) The underground feeder,

9) Transformer CT-4,

10) Both SK breakers,

11) Both standby buses,

12) Both S breakers, and

13) ACB-3 to ACB-4 interlock.

OCONEE UNITS 1, 2, & 3 B 3.8.1-5 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES LCO This LCO is modified by three Notes. Note 1 indicates that a unit startup (continued) transformer may be shared with a unit in MODES 5 and 6. Note 2 indicates that the requirements of Specification 5.5.18, "KHU Commercial Power Generation Testing Program," shall be met for commercial KHU power generation. Note 3 indicates that the requirements of Specification 5.5.19, "Lee Combustion Turbine Testing Program," shall be met when a Lee Combustion Turbine (LCT) is used to comply with Required Actions.

APPLICABILITY The AC power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of accidents and transients, and

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated accident.

AC source requirements during MODE 5 and 6 are covered in LCO 3.8.2, AC Sources-Shutdown.

ACTIONS The ACTIONS are modified by a Note. The Note dxcludes the MODE change restriction of LCO 3.0.4 when both standby buses are energized from an LCT via an isolated power path to comply with Required Actions.

This exception allow entry into an applicable MODE while relying on the ACTIONS even though the ACTIONS may eventually require a unit shutdown. This exception is acceptable due to the additional capabilities afforded when both standby buses are energized from an LCT via an isolated power path.

A.1. A.2, A.3.1. and A.3.2 In the event a startup transformer becomes inoperable, it effectively causes the emergency overhead power path and both of the offsite sources to be inoperable. A KHU and its required underground power path remain available to ensure safe shutdown of the unit in the event of a transient or accident without a single failure.

OCONEE UNITS 1, 2, & 3 B 3.8.1-6 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS A.1, A.2. A.3.1. and A.3.2 (continued)

Operation may continue provided the KHU and its required underground emergency power path are tested using SR 3.8.1.3 within one hour if not performed in the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This Required Action provides assurance that no undetected failures have occurred in the KHU and its required underground emergency power path. Since Required Action A.1 only specifies "perform," a failure of SR 3.8.1.3 acceptance criteria does not result in a Required Action not met. However, if the KHU and its required underground emergency path fails SR 3.8.1.3, both emergency power paths and both required offsite circuits are inoperable, and Condition I for both KHUs and their required emergency power paths inoperable for reasons other than Condition G and H is entered concurrent with Condition A.

If available, another Unit's startup transformer should be aligned to supply power to the affected Unit's auxiliaries so that offsite power sources and the KHU and its required overhead emergency power path will also be available if needed. Although this alignment restores the availability of the offsite sources and the KHU and its required overhead emergency power path, the shared startup transformer's capacity and voltage adequacy could be challenged under certain DBA conditions.

The shared alignment is acceptable because the preferred mode of Unit shutdown is with reactor coolant pumps providing forced circulation and due to the low likelihood of an event challenging the capacity of the shared transformer during a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period to bring a Unit to MODE 5.

Required Action A.3.1 requires that the unit startup transformer be restored to OPERABLE status and normal startup bus alignment in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> or Required Action 3.2 requires designating one unit sharing the startup transformer, to be shutdown. For example, if Unit 1 and 2 are operating and CT-2 becomes inoperable, Unit 2 may align CT-1 to be available to the Unit 2 main feeder buses and continue operating for up to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. At that time, if CT-2 has not been restored to OPERABLE status, one Unit must be designated" to be shutdown. The designated Unit must be shut down per ACTION B. Note that with one Unit in MODES 1, 2, 3 or 4 and another Unit in a condition other than MODES 1, 2, 3, or 4, the units may share a startup transformer indefinitely provided that the loads on the unit not in MODES 1, 2, 3 or 4 are maintained within acceptable limits. For example, if Unit 1 is in MODE 5 and CT-2 becomes inoperable, Unit 2 may align CT-1 to the Unit 2 main feeder buses and continue operation indefinitely.

OCONEE UNITS 1, 2, & 3 B 3.8.1-7 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS B.1 and B.2 (continued)

When a unit is designated to be shutdown due to sharing a unit startup transformer per Required Action A.3.2, the unit must be brought to a MODE in which the LCO does not apply, since the shared unit startup transformer's capacity could be challenged under certain DBA conditions.

To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1, C.2.1, C.2.2.1, C.2.2.2, C.2.2.3. C.2.2.4. and C.2.2.5 With the KHU or its required overhead emergency power path inoperable due to reasons other than an inoperable startup transformer (Condition A), sufficient AC power sources remain available to ensure safe shutdown of the unit in the event of a transient or accident. Operation may continue if the OPERABILITY of the remaining KHU and its required underground emergency power path is determined by performing SR 3.8.1.3 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if not performed in the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once every 7 days thereafter. This demonstration assures the remaining emergency power path is not inoperable due to a common cause or other failure. Testing on a 7 day Frequency is acceptable since both standby buses must be energized from an LCT via an isolated power path when in Condition C for > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. When the standby buses are energized by an LCT via an isolated power path, the likelihood that the OPERABLE KHU and its required underground emergency power path will be required is decreased. Since Required Action C.1 only specifies Nperform," a failure of SR 3.8.1.3 acceptance criteria does not result in a Required Action not met. SR 3.8.1.3 is only required to be performed when the KHU associated with the underground emergency power path is OPERABLE.

If the KHU and its required underground emergency path fails SR 3.8.1.3, both KHUs and their required emergency power paths are inoperable, and Condition I (Both KHUs or their required emergency power paths inoperable for reasons other than Condition G or H) is entered concurrent with Condition C.

OCONEE UNITS 1, 2, & 3 B 3.8.1-8 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS C.1, C.2.1, C.2.2.1, C.2.2.2, C.2.2.3, C.2.2.4, and C.2.2.5 (continued)

If the inoperable KHU or its required overhead emergency power path are not restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by Required Action C.2.1, a controlled shutdown must be initiated as required by the Required Actions for Condition M unless the extended Completion Times of Required Action C.2.2.5 are applicable. The second Completion Time for Required Action C.2.1 establishes a limit on the maximum time allowed for a KHU to be inoperable during any single contiguous occurrence of having a KHU inoperable. If Condition C is entered as a result of switching an inoperable KHU from the underground to the overhead emergency power path, it may have been inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This could lead to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> since the initial failure of the KHU. The second Completion Time allows for an exception to the normal "time zero' for beginning the allowed time 'clock." This will result in establishing the "time zero" at the time the KHU become inoperable, instead of at the time Condition C was entered.

The extended Completion Times of Required Action C.2.2.5 apply when the KHU or its required overhead emergency power path is inoperable due to an inoperable Keowee main step-up transformer or an inoperable KHU (if not used for that KHU in the previous 3 years). In order to use the extended Completion Times, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of entering Condition C both standby buses must be energized from an LCT (Required Action C.2.2.1), KHU generation to the grid except for4esting must be suspended (Required Action C.2.2.2), the remaining KHU and its required underground emergency power path and both required offsite sources must be verified OPERABLE, the LCOs indicated inr Required Action C.2.2.3 must be verified to be met, and alternate power source capability must be verified by performing SR 3.8.1.16.

Required Action C.2.2.5 permits maintenance and repair of a Keowee main step-up transformer which requires longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Transformer replacement is rare but is time extensive. A 28 day Completion Time is permitted by Required Action C.2.2.5 to restore the KHU and its overhead power path to OPERABLE status when inoperable due to an inoperable Keowee main step-up transformer. This allows a reasonable period of time for transformer replacement.

Required Action C.2.2.5 also permits maintenance and repair of a KHU which requires longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The primary long term maintenance items are expected to be hydro turbine runner and discharge ring welding OCONEE UNITS 1, 2, & 3 B 3.8.1-9 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS C.1. C.2.1, C.2.2.1, C.2.2.2, C.2.2.3. C.2.2.4, and C.2.2.5 (continued) repairs which are estimated to be necessary every six to eight years.

Also, generator thrust and guide bearing replacements are necessary.

Other items which manifest as failures are expected to be rare and may be performed during the permitted maintenance periods. As such, the 45 day restoration time of Required Action C.2.2.5 is allowed only once in a three year period for each KHU. This Completion Time is 45 days from discovery of initial inoperability of the KHU. This effectively limits the time the KHU can be inoperable to 45 days from discovery of initial inoperability rather than 45 days from entry into Condition C and precludes any additional time that may be gained as a result of switching an inoperable KHU from the underground to the overhead emergency power path. The 45 day Completion Time is modified by a note indicating that an additional 17 days is allowed when Condition C is entered to perform KHU Refurbishment Upgrades prior to April 30, 2005, except during March, April, May, or June. These upgrades include, but are not limited to, hydro turbine runner and discharge ring weld repair, governor, exciter and battery replacement, and an out-of-tolerance logic circuit modification. The additional 17 days is allowed to be used once for each KHU for upgrade work performed prior to April 30, 2005.

Required Actions C.2.2.1, C.2.2.2, C.2.2.3, and C.2.2.4 must be met in order to allow the longer restoration times of Required Action C.2.2.5.

Required Action C.2.2.1 requires that both standby buses be energized using an LCT through the 100 kV transmission circuit. With this arrangement (100 kV transmission circuit electrically separated from the system grid and all offsite loads), a high degree of reliability for the emergency power system is provided. In this configuration, the LCT is serving as a second emergency power source, however, since the 100 kV transmission circuit is vulnerable to severe weather a time limit is imposed. The second Completion Time of Required Action C.2.2.1 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost. Required Action C.2.2.2 requires suspension of KHU generation to the grid except for testing.

The restriction reduces the number of possible failures which could cause loss of the underground emergency power path. Required Action C.2.2.3 requires verifying by administrative means that the remaining KHU and its required underground emergency power path and both required offsite sources are OPERABLE. This provides additional assurance that offsite power will be available. In addition, this assures that the KHU and its required underground emergency power path are available.

Required Action C.2.2.3 also requires verifying by administrative means that the requirements of the following LCOs are met:

OCONEE UNITS 1, 2, & 3 B 3.8.1 -10 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS C.1, C.2.1, C.2.2.1, C.2.2.2. C.2.2.3, C.2.2.4. and C.2.2.5 (continued)

LCO 3.8.3, 'DC Sources - Operating;"

LCO 3.8.6, "Vital Inverters - Operating;"

LCO 3.8.8, "Distribution Systems - Operating;'

LCO 3.3.17, "EPSL Automatic Transfer Function;"

LCO 3.3.18, "EPSL Voltage Sensing Circuits;"

LCO 3.3.19, "EPSL 230 kV Switchyard DGVP;" and LCO 3.3.21, "EPSL Keowee Emergency Start Function."

This increases the probability, even in the unlikely event of an additional failure, that the DC power system and the 120 VAC Vital Instrumentation power panelboards will function as required to support EPSL, power will not be lost to ES equipment, and EPSL will function as required.

Required Action C.2.2.3 is modified by a Note indicating that it is not applicable to the remaining KHU and its required underground emergency power path or LCO 3.3.21 when in Condition H to perform Keowee Refurbishment Upgrades. Administrative verification is not required when in the Completion Time of Condition H since the KHU associated with the underground emergency power path is not OPERABLE while in Condition H. OPERABILITY of that KHU will be demonstrated prior to returning to service. When in Condition H there is no need to verify LCO 3.3.21 is met since the function serves no purpose when both KHUs are inoperable.

Verifying by administrative means allows a check of logs or other information to determine the OPERABILITY status of required equipment in place of requiring unique performance of Surveillance Requirements.

If the AC Source is subsequently determined inoperable, or an LCO stated in Required Action C.2.2.3 is subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L.

Required Action C.2.2.4 requires verifying alternate power source capability by performing SR 3.8.1.16. This confirms that entry into Condition C is due only to an inoperable main step-up transformer or an inoperable KHU, as applicable. If SR 3.8.1.16 is subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L. This Required Action is modified by a Note OCONEE UNITS 1, 2, & 3 B 3.8.1 -1 1 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS C.1, C.2.1. C.2.2.1, C.2.2.2, C.2.2.3, C.2.2.4, and C.2.2.5 (continued)

(continued) indicating that it is not applicable when in Condition H to perform Keowee Refurbishment Upgrades since the KHU associated with the underground emergency power path is not OPERABLE while in Condition H. The alternate power source capability will be verified prior to returning the KHU to service.

D.1, D.2 and D.3 With the KHU or its required underground emergency power path inoperable, sufficient AC power sources remain available to ensure safe shutdown of the unit in the event of a transient or accident. Operation may continue for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the remaining KHU and its required overhead emergericy power path are tested using SR 3.8.1.4 within one hour if not performed in the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. SR 3.8.1.4 is only required to be performed when the KHU associated with the overhead emergency power path is OPERABLE. This Required Action provides assurance that no undetected failures have occurred in the overhead emergency power path. Since Required Action D.1 only specifies "perform," a failure of SR 3.8.1.4 acceptance criteria does not result in a Required Action not met. However, if the KHU and its required overhead emergency path fails SR 3.8.1.4, both KHUs and their required emergency power paths are inoperable, and Condition I for both KHUs and their emergency power paths inoperable for reasons other than Condition G or H is entered concurrent with Condition D. This demonstration is to assure that the remaining emergency power path is not inoperable due to a common cause or due to an undetected failure.

For outages of the KHU and its required underground emergency power path in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an LCT (using the 100 kV transmission circuit electrically separated from the grid and offsite loads) must energize a standby bus prior to the outage exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This ensures the availability of a power source on the standby buses when the KHU and its required underground emergency power path are out of service in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The second Completion Time of Required Action D.2 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost.

The second Completion Time for Required Action D.3 establishes a limit on the maximum time allowed for a KHU to be inoperable during any single contiguous occurrence of having a KHU inoperable. If Condition D is entered as a result of switching an inoperable KHU from the overhead to the underground emergency power path, it may have been inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This could lead to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> since the initial failure of the KHU. The second Completion Time allows for an exception OCONEE UNITS 1, 2, & 3 B 3.8.1-12 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS D.1, D.2 and D.3 (continued) to the normal "time zero" for beginning the allowed time "clock." This will result in establishing the "time zero" at the time the KHU become inoperable, instead of at the time Condition D was entered.

The first and second Completion Time for Required Action D.3 is modified by a Note indicating that the extended Completion Time of Required Action H.2 is applicable in lieu of these Completion Times when in Condition H to isolate, test and unisolate the KHUs during each of the two KHU Refurbishment Outages. This Note complements the H.2 Note and is necessary to allow continued operation in Condition D while in Condition H. Otherwise, the Completion Time for one inoperable KHU would expire before the Completion Time for two KHUs inoperable and entry into Condition M would be required.

E.1 and E.2 If the Required Action and associated Completion Time for Required Action D.2 are not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for one Oconee unit and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for other Oconee unit(s) and to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1 and F.2 With the zone overlap protection circuitry inoperable when the overhead electrical disconnects for the KHU associated with the underground power path are closed, the zone overlap protection circuitry must be restored to OPERABLE status or the overhead electrical disconnects must be opened within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, both KHUs and their required emergency power paths are OPERABLE, however a single failure could result in the loss of both KHUs.

G.1 With both emergency power paths inoperable due to an E breaker and S breaker inoperable on the same main feeder bus, one breaker must be restored to OPERABLE status. In this Condition, both emergency power paths can still provide power to the remaining main feeder bus.

OCONEE UNITS 1, 2, & 3 B 3.8.1-13 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS H.1 and H.2 (continued)

With both KHUs or their required emergency power paths inoperable for planned maintenance or test with both standby buses energized from an LCT via an isolated power path, the KHU must be restored to OPERABLE status within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />. The 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> Completion Time is modified by a Note indicating that an additional cumulative 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> is allowed when Condition entered to isolate, test and un-isolate the KHUs during each of the two KHU Refurbishment Upgrades prior to April 30, 2005 provided the following conditions are met: 1) period of use not in March, April, May or June; 2) the SSF, EFW System and LCTs (4C, 5C, and 6C) are verified OPERABLE prior to entering Condition; 3) RCS inventory is not reduced (RCS < 50" on LT-5); 4) the SSF is manned; 5) a Jocassee Hydro Unit is verified available to provide power prior to entering Condition; 6) a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> SSF DG operability test is performed prior to the start of the first dual unit outage; and 7) the Completion Time shall only be extended twice during each KHU Refurbishment Outage. For example, if 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> (an additional 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) is required to isolate the KHUs then 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> (an additional 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) is allowed to unisolate and test the KHU. If one of the systems/components in Item 2 (SSF, EFW System and LCTs) above becomes inoperable or in Item 5 above becomes unavailable after entering the condition, immediate action should be taken to restore the equipment to OPERABLE/available status. The Keowee Refurbishment Upgrades include, but are not limited to, hydro turbine runner and discharge ring weld repair, governor, exciter and battery replacement, and an out-of-tolerance logic circuit modification. Operation with both KHUs and their required power paths inoperable is permitted for 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> or the modified Completion Time allowed by the note provided that both standby buses are energized using an LCT through the 100 kV transmission circuit and the requirements of the Note to the Condition are met. The Note to the Condition indicates that it may only be entered when both offsite sources are verified by administrative means to be OPERABLE and the requirements of the following LCOs are verified by administrative means to be met:

LCO 3.8.3, 'DC Sources - Operating;"

LCO 3.8.6, "Vital Inverters - Operating;"

LCO 3.8.8, Distribution Systems - Operating;"

LCO 3.3.17, "EPSL Automatic Transfer Function;"

LCO 3.3.18, "EPSL Voltage Sensing Circuits;" and LCO 3.3.19, "EPSL 230 kV Switchyard DGVP."

OCONEE UNITS 1,2, &3 B 3.8.1-14 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS H.1 and H.2 (continued)

This increases the probability, even in the unlikely event of an additional failure, that the DC power system and the 120 VAC Vital Instrumentation power panelboards will function as required to support EPSL, power will not be lost to ES equipment, and EPSL will function as required.

Verifying by administrative means allows a check of logs or other information to determine the OPERABILITY status of required equipment in place of requiring unique performance of Surveillance Requirements.

If the AC Source is subsequently determined inoperable, or an LCO stated in the Note to Condition H is subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L.

With both standby buses energized from an LCT via an isolated power path (100 kV transmission circuit electrically separated from the system grid and all offsite loads), a high degree of reliability for the emergency power system is provided. In this configuration, the LCT is serving as a second emergency power source, however, since the Oconee Units are vulnerable to a single failure of the 100 kV transmission circuit a time limit of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> is imposed. Required Action H.1 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost.

If both emergency power paths are restored, unrestricted operation may continue. If only one power path is restored, operation may continue per ACTIONS C or D.

1.1. 1.2. and 1.3 With both KHUs or their required emergency power paths inoperable for reasons other than Conditions G and H, insufficient standby AC power sources are available to supply the minimum required ES functions. In this Condition, the offsite power system is the only source of AC power available for this level of degradation. The risk associated with continued operation for one hour without an emergency power source is considered acceptable due to the low likelihood of a LOOP during this time period, and because of the potential for grid instability caused by the simultaneous shutdown of all three units. This instability would increase the probability of a total loss of AC power. Operation with both KHUs or their required power paths inoperable is permitted for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided that Required Actions 1.1 and 1.2 are met. Required Action 1.1 requires that both standby buses be energized using an LCT via an isolated power OCONEE UNITS 1, 2, & 3 B 3.8.1-1 5 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS 1.1, 1.2, and 1.3 (continued) path. With this arrangement (100 kV transmission circuit electrically separated from the system grid and all offsite loads), a high degree of reliability for the emergency power system is provided. In this configuration, the LCT is serving as a second emergency power source, however, since the Oconee Units are vulnerable to a single failure of the 100 kV transmission circuit a time limit of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is imposed. The second Completion Time of Required Action 1.1 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost. Required Action 1.2 requires that the OPERABILITY status of both offsite sources be determined by administrative means and that the OPERABILITY status of equipment required by the following LCOs be determined by administrative means:

LCO 3.8.3, "DC Sources - Operating;"

LCO 3.8.6, "Vital Inverters - Operating;'

LCO 3.8.8, "Distribution Systems - Operating;"

LCO 3.3.17, "EPSL Automatic Transfer Function;"

LCO 3.3.18, "EPSL Voltage Sensing Circuits;" and

. ~..

LCO 3.3.19, "EPSL 230 kV Switchyard DGVP."

This increases the probability, even in the unlikely event of an additional failure, that the DC power system and the 120 VAC Vital Instrumentation power panelboards will function as required to support EPSL, power will not be lost to ES equipment, and EPSL will function as required.

Determining by administrative means allows a check of logs or other information to determine the OPERABILITY status of required equipment in place of requiring unique performance of Surveillance Requirements.

If the AC Source is initially or subsequently determined inoperable, or an LCO stated in Required Action 1.2 is initially or subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L.

If both emergency power paths are restored, unrestricted operation may continue. If only one power path is restored, operation may continue per ACTIONS C or D.

OCONEE UNITS 1, 2, & 3 B 3.8.1-1 6 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS J.1. J.2. and J.3 (continued)

With one or both required offsite sources inoperable for reasons other than Condition A, sufficient AC power sources are available to supply necessary loads in the event of a DBA. However, since the AC power system is degraded below the Technical Specification requirements, a time limit on continued operation is imposed. With only one of the required offsite sources OPERABLE, the likelihood of a LOOP is increased such that the Required Actions for all required offsite circuits inoperable are conservatively followed. The risk associated with continued operation for one hour without a required offsite AC source is considered acceptable due to the low likelihood of a LOOP during this time period, and because of the potential for grid instability caused by the simultaneous shutdown of all three units.

Operation with one or both required offsite sources inoperable is permitted for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided that Required Actions J.1 and J.2 are met. Required Action J.1 requires that both standby buses be energized using an LCT via an isolated power path. With this arrangement (100 kV transmission circuit electrically separated from the system grid and all offsite loads), a high degree of reliability for the emergency power system is provided. In this configuration, the LCT is serving as an emergency power source, however, since the Oconee units are vulnerable to a single failure of the 100 kV transmission circuit a time limit is imposed. The second Completion Time of Required Action J.1 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost. Required Action J.2 requires that the OPERABILITY status of both KHUs and their required emergency power paths be determined by administrative means and that the OPERABILITY status of equipment required by the following LCOs be determined by administrative means:

LCO 3.8.3, 'DC Sources - Operating;"

LCO 3.8.6, "Vital Inverters - Operating;"

LCO 3.8.8, "Distribution Systems - Operating;'

LCO 3.3.17, "EPSL Automatic Transfer Function;"

LCO 3.3.18, "EPSL Voltage Sensing Circuits;"

LCO 3.3.19, "EPSL 230 kV Switchyard DGVP," and LCO 3.3.21, "EPSL Keowee Emergency Start Function."

OCONEE UNITS 1, 2, & 3 B 3.8.1-17 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES ACTIONS J.1, J.2, and J.3 (continued)

This increases the probability, even in the unlikely event of an additional failure, that the DC power system and the 120 VAC Vital Instrumentation power panelboards will function as required to support EPSL, power will not be lost to ES equipment, and EPSL will function as required.

Determining by administrative means allows a check of logs or other information to determine the OPERABILITY status of required equipment in place of requiring unique performance of Surveillance Requirements.

If the AC Source is initially or subsequently determined inoperable, or an LCO stated in Required Action J.2 is initially or subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L.

K.1 The two trip circuits for each closed N and SL breakers are required to ensure both breakers will open. An N breaker trip circuit encompasses those portions of the breaker control circuits necessary to trip the associated N breaker from the output of the 2 out of 3 logic matrix formed by the auxiliary transformer's undervoltage sensing circuits up to and including an individual trip coil for the associated N breaker. The undervoltage sensing channels for the auxiliary transformer are addressed in LCO 3.3.18, "Emergency Power Switching Logic (EPSL)

Voltage Sensing Circuits." An SL breaker trip circuit encompasses those portions of the breaker control circuits necessary to trip the SL breaker from the output of both 2 out of 3 logic matrices formed by each standby bus's undervoltage sensing circuits up to and including an individual trip coil for the associated SL breaker. The undervoltage sensing channels for the CT- 5 transformer are addressed in LCO 3.3.18, "Emergency Power Switching Logic (EPSL) Voltage Sensing Circuits.' With one trip circuit inoperable a single failure could cause an N or SL breaker to not open. This could prevent the transfer to other available sources.

Therefore, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to repair the trip circuit or open the breaker (opening the breaker results in exiting the Condition). The Completion Time is based on engineering judgement taking into consideration the time required to complete the required action and the availability of the remaining trip circuit.

A Note modifies the Condition, indicating that separate Condition Entry is permitted for each breaker. Thus, Completion Times are tracked separately for the N1, N2, SL1, and SL2 breaker.

OCONEE UNITS 1, 2, & 3 B 3.8.1-1 8 Amendment Nos.

AC Sources - Operating B 3.8.1 BASES ACTIONS L.1, L.2, and L.3 (continued)

With an AC Source inoperable or LCO not met, as stated in Note for Condition H entry; or with an AC Source inoperable or LCO not met, as stated in Required Action C.2.2.3 when in Condition C for > 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or with an AC Source inoperable or LCO not met, as stated in Required Action 1.2 or J.2 when in Conditions I or J for > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; or with SR 3.8.1.16 not met, Required Action L.1, L.2 and L.3 requires restoration within four hours. Condition L is modified by a Note indicating that separate Condition entry is permitted for each inoperable AC Source, and LCO or SR not met. The Required Action is modified by a Note that allows the remaining OPERABLE KHU and its required emergency power path to be made inoperable for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if required to restore both KHUs and their required emergency power paths to OPERABLE status.

This note is necessary since certain actions such as dewatering the penstock may be necessary to restore the inoperable KHU although these actions would also cause both KHUs to be inoperable.

The purpose of this Required Action is to restrict the allowed outage time for an inoperable AC Source or equipment required by an LCO when in Conditions C, H, I or J. For Conditions I and J when the LCOs stated are initially not met, the maximum Completion Time is four hours or the remaining Completion Time allowed by the stated LCO, whichever is shorter.

M.1 and M.2 If a Required Action and associated Completion Time for Condition C, F, G, H, I, J, K or L are not met; or if a Required Action and associated Completion Time are not met for Required Action D.1 or D.3, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.8.1.1 REQUIREMENTS This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are OCONEE UNITS 1, 2, & 3 B 3.8.1-1 9 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.1 (continued)

REQUIREMENTS connected to their power source, and that appropriate separation of offsite sources is maintained. The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.

SR 3.8.1.2 This SR verifies adequate battery voltage when the KHU batteries are on float charge. This SR is performed to verify KHU battery OPERABILITY.

The Frequency of once per 7 days is consistent with manufacturers recommendations and IEEE-450 (Ref. 8).

SR 3.8.1.3 This SR verifies the availability of the KHU associated with the underground emergency power path to start automatically and energize the underground power path. Utilization of either the auto-start or emergency start sequence assures the control function OPERABILITY by verifying proper speed control and voltage. Power path verification is included to demonstrate breaker OPERABILITY from the KHU onto the standby buses. This is accomplished by closing the Keowee Feeder Breakers (SK) to energize each deenergized standby bus. The 31 day Frequency is adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

SR 3.8.1.4 This surveillance verifies the availability of the KHU associated with the overhead emergency power path. Utilization of either the auto-start or emergency start sequence assures the control function OPERABILITY by verifying proper speed control and voltage. The ability to supply the overhead emergency power path is satisfied by demonstrating the ability to synchronize (automatically or manually) the KHU with the grid system.

The SR also requires that the underground power path be energized after removing the KHU from the overhead emergency power path. This surveillance can be satisfied by first demonstrating the ability of the KHU associated with the underground emergency path to energize the underground path then synchronizing the KHU to the overhead emergency power path. The SR is modified by a Note indicating that the requirement to energize the underground emergency power path is not OCONEE UNITS 1, 2, & 3 B 3.8.1-20 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.4 (continued)

REQUIREMENTS applicable when the overhead disconnects are open for the KHU associated with the underground emergency power path or 2) when complying with Required Action D.1. The latter exception is necessary since Required Action D.1 continues to be applicable when both KHUs are inoperable.

The 31 day Frequency for this Surveillance was determined to be adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

SR 3.8.1.5 This surveillance verifies OPERABILITY of the trip functions of each closed SL and each closed N breaker. Neither of these breakers have any automatic close functions; therefore, only the trip coils require verification. Cycling of each breaker demonstrates functional OPERABILITY and the coil monitor circuits verify the integrity of each trip coil. The 31 day frequency is based on operating experience.

This SR modified by a Note that states it is not required to be performed for an SL breaker when its standby bus is energized from a LCT via an isolated power path. This is necessary since the standby buses are required to be energized from a LCT by several Required Actions of Specification 3.8.1 and the breakers must remain closed to energize the standby buses from a LCT.

SR 3.8.1.6 Infrequently used source breakers are cycled to ensure OPERABILITY.

The Standby breakers are to be cycled one breaker at a time to prevent inadvertent interconnection of two units through the standby bus breakers. Cycling the startup breakers verifies OPERABILITY of the breakers and associated interlock circuitry between the normal and startup breakers. This circuitry provides an automatic, smooth, and safe transfer of auxiliaries in both directions between sources. The 31 day Frequency for this Surveillance was determined to be adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

This SR is modified by a Note which states the SR is not required to be performed for an S breaker when its standby bus is energized from a LCT via an isolated power path. This is necessary since the standby OCONEE UNITS 1, 2, & 3 B 3.8.1-21 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.6 (continued)

REQUIREMENTS buses are required to be energized from a LCT by several Required Actions of Specification 3.8.1 and cycling the S breakers connects the standby buses with the main feeder buses which are energized from another source.

SR 3.8.1.7 The KHU tie breakers to the underground path, ACB3 and ACB4, are interlocked to prevent cross-connection of the KHU generators. The safety analysis utilizes two independent power paths for accommodating single failures in applicable accidents. Connection of both generators to the underground path compromises the redundancy of the emergency power paths. Installed test logic is used to verify a circuit to the close coil on one underground ACB does not exist with the other underground ACB closed. The 12 month Frequency for this surveillance is adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

SR 3.8.1.8 Each KHU tie breaker to the underground emergency power path and tie breaker to the overhead emergency path, are interlocked to prevent the unit associated with the underground circuit from automatically connecting to the overhead emergency power path. The safety analysis utilizes two independent power paths for accommodating single failures in applicable accidents. Connection of both generators to the overhead emergency power path compromises the redundancy of the emergency power paths. Temporary test instrumentation is used to verify a circuit to the close coil on the overhead ACB does not exist with the Underground ACB closed. The 12 month Frequency for this Surveillance was determined to be adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

SR 3.8.1.9 This surveillance verifies the KHUs' response time to an Emergency Start signal (normally performed using a pushbutton in the control room) to ensure ES equipment will have adequate power for accident mitigation.

UFSAR Section 6.3.3.3 (Ref. 9) establishes the 23 second time requirement for each KHU to achieve rated frequency and voltage. Since the only available loads of adequate magnitude for simulating a accident OCONEE UNITS 1, 2, & 3 B 3.8.1-22 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.9 (continued)

REQUIREMENTS is the grid, subsequent loading on the grid is required to verify the KHU's ability to assume rapid loading under accident conditions. Sequential block loads are not available to fully test this feature. This is the reason for the requirement to load the KHUs at the maximum practical rate. The 12 month Frequency for this SR is adequate based on operating experience to provide reliability verification without excessive equipment cycling for testing.

This SR is modified by a Note that allows the upper limits on KHU frequency and voltage to not be met until the NRC issues an amendment which removes this Note, with the license amendment request to be submitted no later than April 5, 2001.delays the implementation of the surveillance requirement until the KHU digital governor modification is implemented. The acceptance testing for the modification will verify that the limits in the SR are met.

SR 3.8.1.10 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency of 12 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 6) and Regulatory Guide 1.129 (Ref. 7), which state that the battery service test should be performed with intervals between tests not to exceed 18 months.

SR 3.8.1.11 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The 12 month Frequency for this SR is consistent with manufacturers recommendations and IEEE-450 (Ref. 8), which recommends detailed visual inspection of cell condition and rack integrity on a yearly basis.

OCONEE UNITS 1, 2, & 3 B 3.8.1-23 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.12 REQUIREMENTS (continued) Verification of cell to cell connection cleanliness, tightness, and proper coating with anti-corrosion grease provides an indication of any abnormal condition, and assures continued OPERABILITY of the battery. The 12 month frequency is based on engineering judgement and operational experience and is sufficient to detect cell connection degradation when it is properly coupled with other surveillances more frequently performed to detect abnormalities.

SR 3.8.1.13 The KHU underground ACBs have a control feature which will automatically close the KHU, that is pre-selected to the overhead path, into the underground path upon an electrical fault in the zone overlap region of the protective relaying. This circuitry prevents an electrical fault in the zone overlap region of the protective relaying from locking out both emergency power paths during dual KHU grid generation. In order to ensure this circuitry is OPERABLE, an electrical fault is simulated in the zone overlap region and the associated underground ACBs are verified to operate correctly. This surveillance is required on a 12 month Frequency. The 12 month Frequency is based on engineering judgement and provides reasonable assurance that the zone overlap protection circuitry is operating properly.

This SR is modified by a Note indicating the SR is only applicable when the overhead disconnects to the underground KHU are closed. When the overhead disconnects to the underground KHU are open, the circuitry preventing the zone overlap protective lockout of both KHUs is not needed.

SR 3.8.1.14 This surveillance verifies OPERABILITY of the trip functions of the SL and N breakers. This SR verifies each trip circuit of each breaker independently opens each breaker. Neither of these breakers have any automatic close functions; therefore, only the trip circuits require verification. The 18 month Frequency is based on engineering judgement and provides reasonable assurance that the SL and N breakers will trip when required.

The SR is modified by a Note indicating that the SR is not required for an SL breaker when its standby bus is energized by a LCT via an isolated power path. This is necessary since the standby buses are required to OCONEE UNITS 1, 2, & 3 B 3.8.1-24 Amendment Nos.

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.14 (continued)

REQUIREMENTS be energized from a LCT by several Required Actions of Specification 3.8.1 and the breakers must remain closed to energize the standby buses from a LCT.

SR 3.8.1.15 This surveillance verifies proper operation of the 230 kV switchyard circuit breakers upon an actual or simulated actuation of the Switchyard Isolation circuitry. This test causes an actual switchyard isolation (by actuation of degraded grid voltage protection) and alignment of KHUs to the overhead and underground emergency power paths. An 18 month Frequency minimizes the impact to the Station and the operating Units which are connected to the 230 kV switchyard. The effect of this SR is not significant because the generator red bus tie breakers and feeders from the Oconee 230 kV.switchyard red bus to the system grid remain closed. Either Switchyard Isolation Channel causes full system realignment, which involves a complete switchyard realignment. To avoid excessive switchyard circuit breaker cycling, realignment and KHU emergency start functions, this SR need be performed only once each SR interval.

This SR is modified by a Note. This Note states the redundant breaker trip coils shall be verified on a STAGGERED TEST BASIS. Verifying the trip coils on a STAGGERED TEST BASIS precludes unnecessary breaker operation and minimizes the impact to the Station and the operating Units which are connected to the 230 kV switchyard.

SR 3.8.1.1 6 This SR verifies by administrative means that one KHU provides an alternate manual AC power source capability by manual or automatic KHU start with manual synchronize, or breaker closure, to energize its non-required emergency power path. That is, when the KHU to the overhead emergency power path is inoperable, the SR verifies by administrative means that the overhead emergency power path is OPERABLE. When the overhead emergency power path is inoperable, the SR verifies by administrative means that the KHU associated with the overhead emergency power path is OPERABLE.

This SR is modified by a Note indicating that the SR is only applicable when complying with Required Action C.2.2.4.

OCONEE UNITS 1, 2, & 3 B 3.8.1-25 Amendment Nos. I

AC Sources - Operating B 3.8.1 BASES (continued)

REFERENCES 1. UFSAR, Section 3.1.39

2. UFSAR, Chapter 16

3. 10 CFR 50.36

4. UFSAR, Chapter 6

5. UFSAR, Chapter 15

6. Regulatory Guide 1.32

7. Regulatory Guide 1.129

8. IEEE-450-1980

9. UFSAR, Section 6.3.3.3 IN OCONEE UNITS 1, 2, & 3 B 3.8.1-26 Amendment Nos. I July 12, 2004 ATTACHMENT 3 MARKUP OF TECHNICAL SPECIFICATION

AC Sources - Operating 3.8.1 ACTIONS CONDITION [ REQUIRED ACTION J COMPLETION TIME C. (continued) C.2.2. Verify by administrative 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> means that the remaining KHU and its required underground

---

NOTE------------- emergency power path Not applicable to remaining KHU / and both required and its required emergency offsite sources are underground power path or LCO OPERABLE and the 3.3.21 when in Condition H to requirements of LCO perform Keowee Refurbishment 3.8.3, "DC Sources-Upgrades. Operating,' LCO 3.8.6, "Vital Inverters-Operating,' LCO 3.8.8, "Distribution Systems-Operating," LCO 3.3.17, "EPSL Automatic Transfer Function," LCO 3.3.18, "EPSL Voltage Sensing Circuits," LCO 3.3.19, "EPSL 230 kV Switchyard DGVP,"

and LCO 3.3.21, "EPSL Keowee Emergency Start Function" are met.

---

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

Not applicable when in Condition H to perform Keowee AND Refurbishment Upgrades.

C.2.2.4 Verify alternate power 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> source capability by performing AND SR 3.8.1.16.

Every 31 days thereafter AND (continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -4 Amendment Nos[-0, 39, & 3J0 ]

AC Sources - Operating 3.8.1 ACTIONS (continued) I CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.2.5 Restore KHU and its 28 days when Condition required overhead due to an inoperable emergency power path Keowee main step-up to OPERABLE status. transformer AND 45 days from discovery of initial inoperability when Condition due to an inoperable KHU if not used for that KHU in the previous 3 years (continued)

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

An additional 17 days is allowed when Condition entered to perform KHU Refurbishment Upgrades prior to April 30, 2005 except during March, April, May or June

---

------- -- /

OCONEE UNITS 1,2, &3 3.8.1 -5 Amendment Nostf3/0, 39j, & 3Jj

AC Sources - Operating 3.8.1 ACTIONS (continued) .

CONDITION EREQUIRED ACTION I COMPLETION TIME D. KHU or its required D.1 Perform SR 3.8.1.4 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if not performed underground power OPERABLE KHU. in previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> path inoperable.

AND D.2 Energize either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> standby bus from LCT via isolated power AND path.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from subsequent discovery of deenergized required standby bus

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

The extended Completion Time of Required Action H.2 is AMfl applicable in lieu of these Completion Times when in Condition H to isolate, test and D.3 Restore KHU and its 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> unisolate the KHUs during each required underground of the two KHU Refurbishment emergency power path AND Outages. to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from discovery of inoperable KHU V \/ \/ \_/-------

4. 4.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for one unit associated Completion Time not met for AND Required Action D.2.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for other unit(s)

AND 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> E.2 Be in MODE 5.

(continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -6 Amendment Nosf O,3j, & 3j l

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. ----------- NOTE----------- H.1 Energize both standby 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of Condition may be buses from LCT via deenergized standby bus entered only when both isolated power path.

required offsite sources are verified by administrative means to AND be OPERABLE and the requirements of LCO H.2 Restore one KHU and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> 3.8.3, "DC its required emergency Sources-Operating;" power path to LCO 3.8.6, "Vital OPERABLE status.

Inverters-Operating;"

LCO 3.8.8, "Distribution Systems-Operating;"

LCO 3.3.17, "EPSL Automatic Transfer -------------------NOTE--

Function;" LCO 3.3.18, , An additional cumulative 120 Ihours is allowed when "EPSL Voltage Sensing Condition entered to isolate, II est and un-isolate the KHUs Circuits;" LCO 3.3.19, \ during each of the two KHU IF I efurbishment Outages prior to "EPSL 230 kV April 30, 2005 provided the foIIlowing conditions are met: 1) period of use not in March, AjI nril,May or June; 2) the SSF, Switchyard DGVP," are EFW System and LCTs are v Drified OPERABLE prior to verified by entering Condition, 3) RCS inIwentory is not reduced, 4) the administrative means to SSF is manned, 5) a JocasseI e Hydro Unit is verified be met. available to provide power pri Dr to entering Condition, 6) a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> SSF DG operability tee3 t is performed prior to the start of the first dual unit outa ]e, and 7) the Completion Time is only extended twice ciuring each KHU Both KHUs or their / Refurbishment Outage.

required emergency -- - -- - -\- -

power paths inoperable for planned maintenance or test with both standby buses energized from LCT via isolated power path.

(continued)

OCONEE UNITS 1, 2, & 3 3.8.1 -8 Amendment Nosj 0, 39, & 3JO j

The 45 day Completion Time is modified by a note indicating that an additional 17 days is allowed Operating when Condition C is entered to perform KHU Refurbishment Upgrades prior to April 30, 2005, B 3.8.1 except during March, April, May, or June. These upgrades include, but are not limited to, hydro BASES turbine runner and discharge ring weld repair, governor, exciter and battery replacement, and an out-of-tolerance logic circuit modification. The additional 17 days Isallowed to be used once for each EHU for uoarade work oerformed orior to Aoril 30. 2005. -. L ACTIONS C.1, C.2.1, C.2.2.1, C.2.2.2, C.2.2.3. C.2.2.4, and C.2.2.5 (continued) repairs which are estimated to be necessary every six to eight years.

Also, generator thrust and guide bearing replacements are necessary.

Other items which manifest as failures are expected to be rare and may be performed during the permitted maintenance periods. As such, the 45 day restoration time of Required Action C.2.2.5 is allowed only once in a three year period for each KHU. This Completion Time is 45 days from discovery of initial inoperability of the KHU. This effectively limits the time the KHU can be inoperable to 45 days from discovery of initial inoperability rather than 45 days from entry into Condition C and precludes any additional time that may be gained as a result of switching an inoperable KHU from the underground to the overhead emergency power path. +

Required Actions C.2.2.1, C.2.2.2, C.2.2.3, and C.2.2.4 must be met in order to allow the longer restoration times of Required Action C.2.2.5.

Required Action C.2.2.1 requires that both standby buses be energized using an LCT through the 100 kV transmission circuit. With this arrangement (100 kV transmission circuit electrically separated from the system grid and all offsite loads), a high degree of reliability for the emergency power system is provided. In this configuration, the LCT is serving as a second emergency power source, however, since the 100 kV transmission circuit is vulnerable to severe weather a time limit is imposed. The second Completion Time of Required Action C.2.2.1 permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in the event this source is subsequently lost. Required Action C.2.2.2 requires suspension of KHU generation to the grid except for testing.

The restriction reduces the number of possible failures which could cause loss of the underground emergency power path. Required Action C.2.2.3 requires verifying by administrative means that the remaining KHU and its required underground emergency power path and both required offsite sources are OPERABLE. This provides additional assurance that offsite power will be available. In addition, this assures that the KHU and its required underground emergency power path are available.tRequired Action C.2.2.3 also requires verifying by administrative means that the requirements of the following LCOs are met:

LCO 3.8.3, "DC Sources - Operating;"

LCO 3.8.6, "Vital Inverters - Operating;'

LCO 3.8.8, "Distribution Systems - Operating;"

~ ~ ~ UIS12&3B381-0AedetNs3/, 0f, & 4o OCONEE UNITS 1,OCONEE~~~~

~

2, & 3 B 3.8.1 -10 Amendment Nos.[3XO, 30fi, &30]

AC Sources - Operating B 3.8.1 BASES ACTIONS C.1, C.2.1, C.2.2.1. C.2.2.2, C.2.2.3. C.2.2.4. and C.2.2.5 (continued)

Required Action C.2.2.3 is LCO 3.3.17, -EPSL Automatic Transfer Function;'

modified by a Note indicating that it is not applicable to the remaining KHU and its required LCO 3.3.18, "EPSL Voltage Sensing Circuits;"

underground emergency power path or LCO 3.3.21 when in LCO 3.3.19, "EPSL 230 kV Switchyard DGVP;" and Condition H to perform Keowee Admrinistrative verification is not LCO 3.3.21, "EPSL Keowee Emergency Start Function."

required when in the Completion Time of Condition H since the This increases the probability, even in the unlikely event of an additional KHU associated with the failure, that the DC power system and the 120 VAC Vital Instrumentation underground emergency power power panelboards will function as required to support EPSL, power will path isnot OPERABLE while In not be lost to ES equipment, and EPSL will function as required.

Conditiion H. OPERABILITY of that KHU will be demonstrated prior to returning to service. Verifying by administrative means allows a check of logs or other When in Condition Hthere is no information to determine the OPERABILITY status of required equipment need to verify LCO 3.3.21 is met in place of requiring unique performance of Surveillance Requirements.

since the function serves no If the AC Source is subsequently determined inoperable, or an LCO purpose when both KHUs are stated in Required Action C.2.2.3 is subsequently determined not met, continued operation up to a maximum of four hours is allowed by ACTION L.

This Required Action is modified by a Note indicating that it is not applicable when in Required Action C.2.2.4 requires verifying alternate power source Condition H to perform capability by performing*SR 3.8.1.16. This confirms that entry into Keowee Refurbishment Condition C is due only to an inoperable main step-up transformer or an Upgrades since the KHU inoperable KHU, as applicable. If SR 3.8.1.16 is subsequently associated with the determined not met, continued operation up to a maximum of four hours underground emergency power is allowed by ACTION L path isnot OPERABLE while i CINL in Condition H. The alternate power source capability will be verified prior to returning the D.1. D.2 and D.3 KHU to service.

With the KHIJ or its required underground emergency power path inoperable, sufficient AC power sources remain available to ensure safe shutdown of the unit in the event of a transient or accident. Operation may continue for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the remaining KHU and its required overhead emergency power path are tested using SR 3.8.1.4 within one hour if not performed in the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. SR 3.8.1.4 is only required to be performed when the KHU associated with the overhead emergency power path is OPERABLE. This Required Action provides assurance that no undetected failures have occurred in the overhead emergency power path. Since Required Action D.1 only specifies OCONEE UNITS 1, 2, & 3 B 3.8.1 -1 1 BASES REVISION DATED 01/31/00 l

AC Sources - Operating B 3.8.1 BASES ACTIONS D.1. D.2 6nd D.3 (continued)

"perform,' a failure of SR 3.8.1.4 acceptance criteria does not result in a Required Action not met. However, if the KHU and its required overhead emergency path fails SR 3.8.1.4, both KHUs and their required emergency power paths are inoperable, and Condition I for both KHUs and their emergency power paths inoperable for reasons other than Condition G or H is entered concurrent with Condition D. This demonstration is to assure that the remaining emergency power path is not inoperable due to a common cause or due to an undetected failure.

For outages of the KHU and its required underground emergency power path in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an LCT (using the 100 kV transmission circuit electrically separated from the grid and offsite loads) must energize a standby bus prior to the outage exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This ensures the availability of a power source on the standby buses when the KHU and its required underground emergency power path are out of service in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The second Completion Time of Required Action D.2 The first and second permits the standby buses to be re-energized by an LCT within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in Completion Time for the event this source is subsequently lost.

Required Action D.3 is modified by a Note indicating The second Completion Time for Required Action D.3 establishes a limit that the extended Completion on the maximum time allowed for a KHU to be inoperable during any Time of Required Action H.2 is single contiguous occurrence of having a KHU inoperable. If Condition D applicable in lieu of these is entered as a result of switching an inoperable KHU from the overhead Completion Times when in to the underground emergency power path, it may have been inoperable unisolate the KHUs during for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This could lead to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> since the initial each of the two KHU failure of the KHU. The second Completion Time allows for an exception Refurbishment Outages. This to the normal "time zero" for beginning the allowed time "clock." This will Note complements the H.2 result in establishing the 'time zero" at the time the KHU become Note and isnecessary to allow inoperable, instead of at the time Condition D was entered.

continued operation in Condition Dwhile in Condition _

H. Otherwise, the Completion Time for one inoperable E.1 and E.2 KHU would expire before the Completion Time for two If the Required Action and associated Completion Time for Required KHUs inoperable and entry Action D.2 are not met, the unit must be brought to a MODE in which the into Condition M would be LCO does not apply. To achieve this status, the unit must be brought to required. at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for one Oconee unit and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for other Oconee unit(s) and to MODE 5 within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

OCONEE UNITS 1, 2, & 3 B 3.8.1 -12 1BA S RISIOIDATED/03/27 /9 l Amendment Nos. I/

AC Sources - Operating B 3.8.1 BASES ACTIONS F.1 and F.2 *1 (continued)

With the zone overlap protection circuitry inoperable when the overhead The 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> Completion Time is electrical disconnects for the KHU associated with the underground modified by a Note indicating that an additional cumulative 120 power path are closed, the zone overlap protection circuitry must be hours Is allowed when Condition restored to OPERABLE status or the overhead electrical disconnects entered to isolate, test and un- must be opened within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, both KHUs and their isolate the KHUs during each of required emergency power paths are OPERABLE, however a single the two KHU Refurbishment Upgrades prior to April 30 2005 failure could result in the loss of both KHUs.

provided the following conditions are met: 1) period of use not In March, April, May or June; 2) the SSF. EFW System and LCTs G.1 (4C,. 5C, and 6C) are verified OPERABLE prior to entering With both emergency power paths inoperable due to an E breaker and S Condition; 3) RCS Inventory is not reduced (RCS < 50" on LT-breaker inoperable on the same main feeder bus, one breaker must be 5); 4) the SSF is manned; 5) a restored to OPERABLE status. In this Condition, both emergency power Jocassee Hydro Unit is verified paths can still provide power to the remaining main feeder bus.

available to provide power prior to entering Condition; 6) a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> SSF DG operability test is performed prior to the start of the first dual unit outage; and 7) the Completion Time is only extended twice during each KHU With both KHUs or their required emergency power paths inoperable for Refurbishment Outage. For planned maintenance or test with both standby buses energized from an example, if 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> (an LCT via an isolated power path, the KHU must be restored to additional 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) is required to isolate the KHUs then 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> OPERABLE status within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.``peration with both KHUs and their (an additional 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) Is required power paths inoperable is permitted for 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> provided that allowed to unisolate and test the both standby buses are energized using an LCT through the 100 kV KHU. If one of the transmission circuit and the requirements of the Note to the Condition are systems/components in Item 2 (SSF, EFW System and LCTs) met. The Note to the Condition indicates that it may only be entered above becomes inoperable or In when both offsite sources are verified by administrative means to be Item 5 above becomes OPERABLE and the requirements of the following LCOs are verified by unavailable after entering the condition, immediate action administrative means to be met:

should be taken to restore the equipment to LCO 3.8.3, "DC Sources - Operating;" or the OPERABLE/available status. modified The Keowee Refurbishment Upgrades Include, but are not LCO 3.8.6, "Vital Inverters - Operating;" C allot limited to, hydro turbine runner by the no, and discharge ring weld repair, governor, exciter and battery LCO 3.8.8, "Distribution Systems - Operating;"

replacement, and an out-of-tolerance logic circuit LCO 3.3.17, "EPSL Automatic Transfer Function;"

modification.

LCO 3.3.18, "EPSL Voltage Sensing Circuits;" and LCO 3.3.19, "EPSL 230 kV Switchyard DGVP."

&~3 ~ ~ B ~..- 3AedetUNT1.2 oI/,0 o3 OCONEE UNITS 1,OCONEE~~~~~~

2, & 3 B 3.8.1-13 Amendment Nosj 3XO, X00,14 39bj July 12, 2004 Page 1 List of Regulatory Commitments The following table identifies those actions committed to by Duke Energy Corporation (Duke) in this letter, the initial August 22, 2002 License Amendment Request (LAR), and subsequent Supplements (September 12, 2003, February 4, February 16, March 23, April 28, and June 17, 2004). Any other statements in these submittals were provided for informational purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Boyd Shingleton at (864) 885-4716.

REGULATORY COMMITMENTS Due Date/Event Keowee Refurbishment Work will be controlled by a Critical Evolution Plan Keowee Refurbishment Outages (CEP)

The compensatory measures committed to by the License Amendment Request Keowee Refurbishment Outages (LAR) and its Supplements will be captured in the CEP for each Keowee Refurbishment Outage The Lee Combustion Turbines (LCTs) not energizing the standby buses will be Keowee Refurbishment Outages on standby should the required LCT become inoperable A LCT will be aligned to energize the standby bus before the emergency power Keowee Refurbishment Outages paths are removed from service During periods when both KHUs are inoperable, one of the two standby LCTs Keowee Refurbishment Outages will be running.

No discretionary maintenance or testing will be performed on the Standby Keowee Refurbishment Outages Shutdown Facility, Emergency Feedwater System, and AC Power System Work on the 230 kV switchyard and transformer yards, and other ORAM-sentinel Keowee Refurbishment Outages risk significant systems associated with AC power availability will be restricted during the single and dual KHU outages.

To the extent practical, maintenance and testing in the switchyard is to be Keowee Refurbishment Outages scheduled outside the time period of the upgrade.

Any maintenance on the Duke system that could affect the Oconee switchyard is Keowee Refurbishment Outages being re-scheduled outside the Keowee outage time frame. l The 30 mile Lee Electrical Transmission Right of Way line segment will receive Keowee Refurbishment Outages danger tree maintenance work for trees located outside the defined R/W width.

The CEP will include criteria related to weather and grid conditions that must be Keowee Refurbishment Outages satisfied prior to the start of the overall Keowec Refurbishment Outage and each of the dual KHU outages The criteria will include a check of the short range weather forecast and grid Keowee Refurbishment Outages conditions The CEP will also specifically address the need to monitor weather and grid Keowee Refurbishment Outages conditions and include appropriate actions based on those conditions and the status of the Keowee units.

The CEP will include steps to verify the RTCA computer program is available Keowee Refurbishment Outages prior to the start of a dual KHU outage.

The CEP will include criteria to determine weather or grid conditions that would Keowee Refurbishment Outages require returning a Keowee unit to service.

Duke will have provisions in place to return a KHU to service should termination Keowee Refurbishment Outages criteria in the CEP be met.

Duke will have provisions in place to allow the return of one KHU to service Keowee Refurbishment Outages should Keowee be without auxiliary power as a result of a loss of power The SSF Pressurizer Heater Capacity modification will be completed prior to the Complete KHU Refurbishment Outages July 12, 2004 Page 2 REGULATORY COMMITMENTS Due Date/Event Duke will verify the system electrical grid status is Yellow or Green and is Keowee Refurbishment Outages expected to remain so for the next three days within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will verify the electrical system reserves are Adequate, Good, or Excellent Keowee Refurbishment Outages and are expected to remain so for the next three days within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will verify there are a minimum of 4 independent power paths (offsite Keowee Refurbishment Outages power lines) into the ONS switchyard within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will verify there are no tornado watches or warnings in the Oconee/Pickens Keowee Refurbishment Outages county area and none are forecast for the next three days within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will verify there are no tropical storms or hurricanes forecasted to affect the Keowee Refurbishment Outages Oconee/Pickens county area for the next three days within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will verify there are no ice storms or conditions that could produce ice Keowee Refurbishment Outages storms in the Oconee/Pickens county area forecasted for the next three days that could produce a radial ice accumulation of %A inch on power lines within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the start of a dual KHU outage.

Duke will immediately evaluate the need to exit a dual KHU outage if the system Keowee Refurbishment Outages electrical status is expected to change to Orange or Red, the electrical system reserves are expected to degrade below Adequate, or less than 4 offsite lines are available prior to the end of the outage.

Duke will immediately evaluate the need to exit a dual KHU outage if a tropical Keowee Refurbishment Outages storm, hurricane, or frontal system that could produce damaging winds or tornados is forecasted for the Oconee/Pickens county area prior to the end of the outage.

Duke will immediately evaluate the need to exit a dual KHU outage if an ice Keowee Refurbishment Outages storm that could produce 1/4 inch of radial ice accumulation on conductors with 30 mph winds or % inch of radial ice accumulation with no winds is forecasted for the Oconee/Pickens county area prior to the end of the outage.

Duke will notify the NRC via the Emergency Notification System (ENS) should Keowee Refurbishment Outages grid or weather related criteria be met that requires Duke to evaluate the need to exit the dual KHU outage.

Duke will provide backup power capability for the Turbine Driven Emergency Keowee Refurbishment Outages Feedwater Pump (TDEFWVP) controls and valves to allow the pumps to continue feeding the Steam Generators on each Oconee Unit beyond the station battery life until a KHU can be restored.