Text

Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Rev. 3, Using the Consolidated Line Item Improvement Process; License Amendment Request No. 2010-07
	ML11299A017
Person / Time
Site:	Oconee
Issue date:	10/13/2011
From:	Gillespie T; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LAR-10-07
	Download: ML11299A017 (55)
	v • d • e

T. PRESTON GILLESPIE, JR.

Duke Vice President Energy@

Oconee Nuclear Station Duke Energy 10 CFR 50.90 ONO IVP / 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 864-873-4208 fax T. Gillespie@duke-energy. corn October 13, 2011 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287, Renewed Operating Licenses DPR-38, DPR-47, and DPR-55 Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process; License Amendment Request No. 2010-07 In accordance with 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy), is submitting a request for an amendment to the Technical Specifications (TS) related to Control Room Envelope Habitability for the Oconee Nuclear Station (ONS). The proposed amendment would modify the TS in accordance with Technical Specification Task Force (TSTF)-448, "Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process." The availability of this TS improvement was published in the Federal Register (72 FR 2022) on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

The Enclosure provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific variations. Attachment 1 provides the existing TS and TS Bases pages marked up to show the proposed changes and Attachment 2 provides the revised TS and TS Bases pages. There are no regulatory commitments made in this submittal.

Duke Energy requests NRC approval of this CLIIP item by June 30, 2012, with a 180-day implementation period.

Specific sections of the ONS Updated Final Safety Analysis Report may require revision as a result of the proposed change. This revision will be submitted pursuant to 10 CFR 50.71(e) requirements.

In accordance with Duke Energy administrative procedures and the Quality Assurance Program Topical Report, these proposed changes have been reviewed and approved by the Plant Operations Review Committee. Additionally, a copy of this LAR was transmitted to the State of South Carolina in accordance with 10 CFR 50.91 requirements.

If you should have any questions regarding this submittal, please contact Stephen C. Newman, Oconee Regulatory Compliance Group, at (864) 873-4388.

www. duke-energy. corn

-Nuclear Regulatory Commission License Amendment Request No. 2010-07 October 13, 2011 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on October 13, 2011.

Sincerely, Teston Gillespie, Jr.

Vice President Oconee Nuclear Station Enclosure Description and Assessment Attachments:

1. Proposed Technical Specification and Bases Changes (Mark-Up).

2. Revised Technical Specification and Bases Pages.

,Nuclear Regulatory Commission License Amendment Request No. 2010-07 October 13, 2011 Page 3 xc w/enclosure/attachments:

Mr. Victor McCree, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. J. F. Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 8 G9A Washington, D. C. 20555 Mr. Andy Sabisch NRC Senior Resident Inspector Oconee Nuclear Station Susan E. Jenkins, Manager Radioactive & Infectious Waste Management SC Dept. of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

ENCLOSURE DESCRIPTION AND ASSESSMENT

Subject:

Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Changes and Variations 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Environmental Evaluation 3.2 Commitments 4.0 ENVIRONMENTAL EVALUATION

Enclosure - Description and Assessment License Amendment Request No. 2010-07 October 13, 2011 Page 2

1.0 DESCRIPTION

This License Amendment Request (LAR) will modify Technical Specification (TS) requirements related to Control Room Envelope (CRE) habitability in TS 3.7.9, "Control Room Ventilation System Booster Fans," and TS Section 5.5, "Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change, TSTF-448, Revision 3. The availability of this TS improvement was published in the Federal Register (72 FR 2022) on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Duke Energy Carolinas, LLC (Duke Energy) has reviewed the Safety Evaluation (SE) dated January 9, 2007 as part of the CLIIP. This review included a review of the NRC's evaluation, as well as the supporting information provided to support TSTF-448. Duke Energy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Oconee Nuclear Station (ONS), Units 1, 2, and 3 and justify this amendment for incorporation of the changes to the ONS TS.

2.2 Changes and Variations Duke Energy is not proposing any significant variations or deviations from the TS changes described in TSTF-448, Revision 3, or the applicable parts of the NRC Staff's model Safety Evaluation (SE) dated January 9, 2007. The following sections of the model SE are applicable to ONS: Evaluation 2, Evaluation 3, Evaluation 4, and Evaluation 6. Duke Energy is proposing the following variances to the changes described in TSTF-448, Revision 3, to reflect known error corrections and specific ONS configuration differences associated with the NRC model:

Variation Justification

1. In applicable sections of To match Oconee Nuclear Station system the TS and TS Bases nomenclature.

(TSB) model, used the term Control Room Ventilation System (CRVS) rather than the Control Room Emergency Ventilation System (CREVS).

,Enclosure - Description and Assessment License Amendment Request No. 2010-07 October 13, 2011 Page 3 Variation~

Justification

2. Reworded "Applicability" Based on the 3 unit/2 control room description as follows:

configuration, a conservative decision made to

"...During movement of ensure the safety of all control room personnel recently irradiated fuel from the effects of a fuel handling accident assemblies for any unit."

occurring at any unit.

Also, revised the TSB applicability section description.

3. TS 3.7.9 Condition B, There are no chemical and smoke limits for the Required Action B.2 ONS control rooms; Consequently, the original wording was revised to:

NRC model verbiage is not applicable. The revised wording is identical to that proposed in "Verify mitigating actions "Response to April 17, 2009, Request for radiological exposures will Additional Information Regarding not exceed limits, and CRE TSTF-508, Revision 0, "Revise Control Room occupants are protected Habitability Actions to Address Lessons from chemical and smoke Learned from TSTF-448 Implementation,"

hazards."

dated June 18, 2009.

4. TS Bases reference date Correction is documented in TSTF-06-37 letter, for NEI 99-03, "Control "Corrected Pages for TSTF-448, Revision 3, Room Habitability Control Room Habitability," dated December Assessment," was 29, 2006.

changed from March 2001, as given in the NRC model, to June 2001. This error was identified in TSTF-448, R3 after issuance.

Enclosure - Description and Assessment License Amendment Request No. 2010-07 October 13, 2011 Page 4 V'ariation

'Justfication

5. The NRC model wording The original statement given in the NRC model given in TS 5.5.18, was incorrect as the assessment being "Control Room Envelope referenced is required (by Regulatory Guide Habitability Program,"

1.197) to be performed every 36 months, not item (d) was changed [in every 18 months. This error was identified part] to read:

shortly before the final approval of TSTF-448

"... The results shall be and acknowledged by the NRC and the trended and used as part industry.

of the periodic The revised wording is identical to that assessment of the CRE proposed in Response to April 17, 2009, boundary."

Request for Additional Information Regarding TSTF-508, Revision 0, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation,"

dated June 18, 2009.

6. Revised certain sections To agree with current licensing basis and of the Technical system configuration.

Specifications (TS) Bases to agree with the Oconee's Booster Fan train system configuration.

7. Relocated the non-In accordance with the March 21, 2011, NRC conditional SR approval of TSTF 425 amendment for the frequencies (3.7.9.1, Oconee Nuclear Station.

3.7.9.3, and 3.7.9.5) to a licensee controlled program. Revised the TSTF - 448 Rev. 3 model wording accordingly.

8. Added verbiage to TSB to Detailed information was requested to be address the CR's smoke added to this section by the ONS Plant and chemical action Operations Review Committee (PORC).

capabilities 2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements Duke Energy proposes the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of the Amendment adopting TSTF-448, Revision 3, the determination of CRE unfiltered air in-leakage as required by TS SR 3.7.9.4, in

Enclosure - Description and Assessment License Amendment Request No. 2010-07 October 13, 2011 Page 5 accordance with TS 5.5.21.c.(i); the assessment of CRE habitability as required by TS 5.5.21.c.(ii); and the measurement of pressure as required by TS 5.5.21.d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.9.4 in accordance with Specification 5.5.21.c.(i), shall be within the specified Frequency of 6 years, plus the 18 month (25%) allowance of SR 3.0.2, as measured from the date of the most recent successful tracer gas test, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years. The most recent successful test as of the date of this submittal is June, 2007.

(b) The first performance of the periodic assessment of CRE habitability, TS 5.5.21.c.(ii), shall be within 3 years, plus the 9 month (25%) allowance of SR 3.0.2, as measured from the date of the most recent successful tracer gas test or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years. The most recent successful test as of the date of this submittal is June, 2007.

(c) The first performance of the periodic measurement of CRE pressure, TS 5.5.21.d shall be within 18 months plus the 4.5 months allowed by SR 3.0.2, as measured from July 5, 2007 for Units 1 and 2 and May 31, 2007 for Unit 3, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Duke Energy has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Duke Energy has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Oconee Nuclear Station and is hereby incorporated by reference.

3.2 Commitments There are no new regulatory commitments contained in this LAR. This LAR satisfies the planned commitment made in Oconee's response to NRC GL 2003-01, dated December 9, 2003, to review and implement TSTF-448 once approved.

4.0 ENVIRONMENTAL EVALUATION Duke Energy has reviewed the environmental evaluation included in the model safety evaluation dated January 9, 2007 as part of the CLIIP. Duke Energy has concluded that the staff's findings presented in that evaluation are applicable to Oconee Nuclear Station and the evaluation is incorporated by reference for this application.

ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION AND BASES PAGES (MARK-UP)

CRVS Booster Fans 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Ventilation System (CRVS) Booster Fans LCO 3.7.9 Two CRVS Booster Fan trains shall be OPERABLE.

-NOTE-The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY:

MODES 1, 2, 3, an=d-4, 5 and 6, During movement of recently irradiated fuel assemblies for any unit.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

C,,ontrolt Room. prS.u.e A. 1 Restore G"e"r-" Re

730 days

!5.9 sig du4 proSSure to >- 0.0 psig t.*n-R n-f tw 0 C-e0ne during opeati*on of tw CRVS Booster Fan train CRVS Booster Fan train inoperable for reasons to OPERABLE other than Condition Bs.

statustFaiAs.

B. One or more CRVS B.1 Restore CRVS Booster Immediately Booster Fan trains Fan train to OPERABLE inoperable due to ltatusInitiate action to inoperable CRE implement mitigating boundary in MODE 1, 2, actions or 4,Fo reasonsother than Con,-dition A.

AND 2472 hours0.0286 days 0.687 hours 0.00409 weeks 9.40596e-4 months B.2 Verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

OCONEE UNITS 1, 2, & 3 3.7.9-1 Amendment Nos. xxx358, xxx360, 4 xxx 359

CRVS Booster Fans 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME 90 days AND B.3 Restore CRE boundary to OPERABLE status.

(continued)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

T-o CRVS Booster Fan C.1 Be in MODE 3.ReetG-e 1224 hours0.0142 days 0.34 hours 0.00202 weeks 4.65732e-4 months trains inprbe fo n

RVS Boce a

reaee.A nttef train to OPERABLE theaRequired Actions statue.

and associated 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Completion Time of AND Condition A or B not met in MODE 1, 2, 3, or 4.

C.2 Be in MODE 5.

D.

Required Actions and D.1 Place OPERABLE Immediately associated Completion CRVS Booster Fan train Time of Condition A not in emergency mode met in MODE 5 or 6, or during movement of OR recently irradiated fuel assemblies.

D.2 Suspend movement of Immediately recently irradiated fuel assemblies.

E.

Two CRVS Booster Fan E.1 Suspend movement of Immediately trains inoperable in recently irradiated fuel MODE 5 or 6, or during assemblies.

movement of recently irradiated fuel assemblies.

OR One or more CRVS OCONEE UNITS 1, 2, & 3 3.7.9-2 Amendment Nos. xxx358, xxx36G, 8 xxx 359

CRVS Booster Fans 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME Booster Fan trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of recently irradiated fuel assemblies.

(continued)

OCONEE UNITS 1, 2, & 3 3.7.9-3 Amendment Nos. xxx358, xxxx

, 4 xxx 3&9

CRVS Booster Fans 3.7.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Two CRVS Booster Fan F.1 Enter LCO 3.0.3.

Immediately trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

(G04R61801 OCONEE UNITS 1, 2, & 3 3.7.9-4 Amendment Nos. xxx358, xxx36w, cxxx 369

CRVS Booster Fans 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME D. Require-d Ac~tion -and-D.1 I Bo in MODE 3.hGF asseocvated Completion Time net met in MODE AND D.2 Be-in MO-)DE-5 3

GF E-

,=R,:,. A,,ion and E.1 Suspend monvement of mmediate!

asseociated Completion recently irradiated fuel Time not mnet during assemblies.

mRovement Of recently assemb~es.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRVS Booster Fan train for In accordance with the

_ 15 minutes.

Surveillance Frequency Control Proqram@2-days SR 3.7.9.2 Perform required CRVS Booster Fan train In accordance with the filter testing in accordance with the Ventilation VFTP Filter Testing Program (VFTP).

SR 3.7.9.3 Manually start each CRVS Booster Fan Train In accordance with the and verify automatic actions.

Surveillance Frequency Control Program SR 3.7.9.4 Perform required CRE unfiltered air inleakaqe In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program.

Habitability Program OCONEE UNITS 1, 2, & 3 3.7.9-5 Amendment Nos. xxxM8, xxx36, 8 xxx &G

CRVS Booster Fans 3.7.9 SURVEILLANCE FREQUENCY SR-3-.Q-SR 3.7.9.53 Verify the system makeup flow rate is In accordance with the

> 1215 and < 1485 cfm when supplying the Surveillance Frequency control room with outside airtwe-GRVS Control Proqram!8 months Boo-nster Fantains can maintain the Control Room at a positive pressure.

OCONEE UNITS 1, 2, & 3 3.7.9-6 Amendment Nos. xxx358, xxx3§W, &[ xxx 358

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Battery Discharge Testing Program (continued)

b.

If battery capacity is determined to be < 80% of the manufacturer's rating an OPERABILITY evaluation shall be initiated immediately and completed within the guidelines of the Oconee OPERABILITY program. If the OPERABILITY evaluation determines the battery OPERABLE, battery capacity shall be restored to >_ 80% of the manufacturer's rating within a time frame commensurate with the safety significance of the issue.

Otherwise, the battery shall be declared inoperable and the applicable Condition of Specification 3.8.3 shall be entered.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Battery Discharge Testing Program surveillance frequencies.

5.5.21 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.22 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Ventilation System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

OCONEE UNITS 1, 2, & 3 5.0-22 Amendment Nos. ;55xxx, 3ý57xxx,

& 356xxx

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Control Room Envelope Habitability Program (continued)

The program shall include the following elements:

a.

The definition of the CRE and the CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determininq the unfiltered air inleakaqe past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adiacent to the CRE boundary during the pressurization mode of operation by one train of the CRVS, operating at the flow rate required by the VFTP, at a frequency in accordance with the Surveillance Frequency Control Program on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

OCONEE UNITS 1, 2, & 3 5.0-23 Amendment Nos. 3-5xxx 3xxx,

& 356xxx

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 5.6.2 Deleted Annual Radioloqical Environmental Operatingq Report K

II A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year.

The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

Amendment Nos. 355xxx, 35-xxx, OCONEE UNITS 1, 2, & 3

& 356xxx 5.0-24

Reporting Requirements 5.6 5.6 Reporting Requirements _(continued) 5.6.3 Radioactive Effluent Release Report

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit in the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.

The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR part 50, Appendix I,Section IV.B.1.

5.6.4 5.6.5 Deleted CORE OPERATING LIMITS REPORT (COLR)

Core operating limits shall be established, determined and issued in accordance with the following:

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

Shutdown Margin limit for Specification 3.1.1;

2.

Moderator Temperature Coefficient limit for Specification 3.1.3;

3.

Physical Position, Sequence and Overlap limits for Specification 3.2.1 Rod Insertion Limits;

4.

AXIAL POWER IMBALANCE operating limits for Specification 3.2.2;

5.

QUADRANT POWER TILT (QPT) limits for Specification 3.2.3; Amendment Nos. 355xxx, *7-xxx, OCONEE UNITS 1, 2, & 3

& 356xxx 5.0-25

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

6.

Nuclear Overpower Flux/Flow/Imbalance and RCS Variable Low Pressure allowable value limits for Specification 3.3.1;

7.

RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits for Specification 3.4.1

8.

Core Flood Tanks Boron concentration limits for Specification 3.5.1;

9.

Borated Water Storage Tank Boron concentration limits for Specification 3.5.4;

10.

Spent Fuel Pool Boron concentration limits for Specification 3.7.12;

11.

RCS and Transfer Canal boron concentration limits for Specification 3.9.1; and

12.

AXIAL POWER IMBALANCE protective limits and RCS Variable Low Pressure protective limits for Specification 2.1.1.

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

(1)

DPC-NE-1002-A, Reload Design Methodology II; (2)

NFS-1001-A, Reload Design Methodology; (3)

DPC-NE-2003-P-A, Oconee Nuclear Station Core Thermal Hydraulic Methodology Using VIPRE-01; (4)

DPC-NE-1004-A, Nuclear Design Methodology Using CASMO-3/SIMULATE-3P; (5)

DPC-NE-2008-P-A, Fuel Mechanical Reload Analysis Methodology Using TACO3; (6)

BAW-1 0192-P-A, BWNT LOCA - BWNT Loss of Coolant Accident Evaluation Model for Once-Through Steam Generator Plants; OCONEE UNITS 1, 2, & 3 5.0-26 Amendment Nos. 3ý5xxx, 3,r-7xxx,

& 356xxx

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

(7)

DPC-NE-3000-P-A, Thermal Hydraulic Transient Analysis Methodology; (8)

DPC-NE-2005-P-A, Thermal Hydraulic Statistical Core Design Methodology; (9)

DPC-NE-3005-P-A, UFSAR Chapter 15 Transient Analysis Methodology; and (10)

BAW-10227-P-A, Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel.

(11)

BAW-10164P-A, RELAP 5/MOD2-B&W -An Advanced Computer Program for Light Water Reactor LOCA and non-LOCA Transient Analysis The COLR will contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (i.e.,

report number, title, revision number, report date or NRC SER date, and any supplements).

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitorinq (PAM) and Main Feeder Bus Monitor Panel (MFPMP)

Report When a report is required by-Condition B or G of LCO 3.3.8, "Post Accident Monitoring (PAM) Instrumentation" or Condition D of LCO 3.3.23, "Main Feeder Bus Monitor Panel," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring (PAM only),

the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Any abnormal degradation of the containment structure detected during the tests OCONEE UNITS 1, 2, & 3 5.0-27 Amendment Nos. 362xxx, 364xxx, &

363xxx

Reporting Requirements 5.6 5.6 Reporting Requirements required by the Pre-stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a Amendment Nos. 362xxx, 364xxx, &

OCONEE UNITS 1, 2, & 3 Wxxx 5.0-28

Reporting Requirements 5.6 5.6 Reporting Requirements description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken.

5.6.8 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 5.5.10, Steam Generator (SG) Program. The report shall include:

a.

The scope of inspections performed on each SG,

b.

Active degradation mechanisms found,

c.

Nondestructive examination techniques utilized for each degradation mechanism,

d.

Location, orientation (if linear), and measured sizes (if available) of service induced indications,

e.

Number of tubes plugged during the inspection outage for each active degradation mechanism,

f.

Total number and percentage of tubes plugged to date,

/

g.

The results of condition monitoring, including the results of tube pulls and in-situ testing, and

h. The effective plugging percentage for all plugging in each SG.

OCONEE UNITS 1,2, & 3 363xxx 5.0-29 Amendment Nos. 362xxx, 364xxx, &

CRVS Booster Fans B 3.7.9 B 3.7 PLANT SYSTEMS B 3.7.9 Control Room Ventilation System (CRVS) Booster Fans BASES BACKGROUND The CRVS Booster Fan trains provide a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity,- hazardous chemicals, or smoke.

The CRVS consists of two redundant Booster Fan trains that supply filtered outdoor air to the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air (Ref 1).

Each CRVS Booster Fan train consists of a filter assembly, booster fan, ductinqg and dampers that supply filtered air to the control room. Each filter train consists of a pre-filter, a high efficiency particulate air (HEPA) filter, a charcoal filter for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. The Unit 1 & 2 CRE encompasses the control room, operator aid computer room, control room offices, restroom operator kitchen, and the technical support center. The Unit 3 CRE encompasses the control room, control room office, operator aid computer room, restroom, operator kitchen, cable room vestibule, and the operations support center. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakaqe assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

Ench CRY IS B,,ster Fan traiRn pro des 50% c.apacity and conAiss of a fan filter assembly, Boos-ter Fans, Dus 1ting, and Dampers. Each filter train cosst f apre filter, a high efficiency particlate air (HEPA) filter, and a rahaGeGalfilter-.

IT-he CRVS Booster Fan trains are an emergency system. Upon receipt of a radiation alarm from the Control Room air radiation monitor, the CRVS Booster Fan trains can be started manually to minimize unfiltered air from entering the control room. Upon starting the fans, dampers are OCONEE UNITS 1, 2, & 3 B 3.7.9-1 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES automatically positioned to isolate the control room. The pre-filters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA and carbon filters.

BACKGROUND Either CRVS Booster Fan train can (Gc.tinued) pressurize the Control Room to (continued) minimize infiltration of unfiltered air. TheCRVS operation is discussed in the UFSAR, Section 9.4 (Ref. 1).

The CRVS Booster Fan trains are designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a DBA, without exceeding a 5 rem total effective dose equivalent (TEDE).

APPLICABLE The CRVS Booster Fan train components are arranged in two ventilation SAFETY ANALYSIS trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CRVS provides airborne radiological protection for the CRE occupants as demonstrated by the CRE occupant dose analysis for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2). Dose calculations (Ref.10) utilize the flowrate for one train and the maximum allowable unfiltered leakage to evaluate CRE occupant radiological protection.

The CRVS Booster Fan trains provide protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 3). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the standby shutdown facility (Ref. 3).

The_ CRVS oote Fan train comnponents are arranged in two ventilation SAFETYý ANhIALYR17SES trainS. The locnation of coempoenets and ducting ensures an adequate 6upply of filtered air to all areas Fequrnace.

The CRVS provides airborne radiological potection fo the contro room operators fo the mo limitirg design basis lo06 Of coolant ac-ident fi.sion product release presented in the UFSAR, Chapter 15 (Ref. 2).

The CRVS Booster Fan trains satisfy Criterion 3 of 10 CFR 50.36 (Ref. 43).

LCO Two CRVS trains are required to be OPERABLE. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE OCONEE UNITS 1, 2, & 3 B 3.7.9-2 Amendment Nos. xxx, xxx, & xxx i

CRVS Booster Fans B 3.7.9 BASES occupants in the event of a large radioactive release.

Each CRVS Booster Fan train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CRVS Booster Fan train is considered OPERABLE when the associated:

TING CRVS train, ae rFequ64ed to be OPERABLE. Total.y.t.*-

failure co.uld re.ult in ex....i d

110 to hCotrol Room oper-atorc in the event of a !arge radioactive OCONEE UNITS 1, 2, & 3 B 3.7.9-3 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES LCO The CRVS Booster Fan tran arcnidered )PERABLE rmWhen the (continued) indivdual com~ponents necessary to cOntrM operator exposure are-OPE9RABLE in both trains. A CRVS Booster Fan train ir, considered OPERABLE when the associated:

a.

Booster Fan is OPERABLE;

b.

HEPA filter and carbon absorber are not excessively restricting flow, and are capable of performing their filtration functions; and OCONEE UNITS 1, 2, & 3 B 3.7.9-4 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES LCO (continued)

c.

Ductwork, valves, and dampers are OPERABLE, and control room unfiltered inleakagqe stMiatcan be maintained within limits.

In order for the CRVS Booster Fan trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a larae radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs and that CRE occupants are protected from hazardous chemicals and smoke.

The LOO is modified by a Note allowing the ORE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openinas, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

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-- r otri rcs NO latl to APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of recently irradiated fuel assemblies, the CRVS Booster Fan trains must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

in MODES 1, 2, 3, and 4, the CRVS-Booster-Fan trains must be OPIERA.BLE to reduae radiation d.os.t*o per.onel in the Con#tol Room during and following an accident.

During movement of recently irradiated fuel assemblies by any unit, the CRVS Booster Fan trains must be OPERABLE to cope with a release due to a fuel handling accident involving handling recently irradiated fuel. Due to radioactive decay, CRVS is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ).

OCONEE UNITS 1, 2, & 3 B 3.7.9-5 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES ACTIONS A.1 With one CRVS Booster Fan train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period and the potential for the OPERABLE CRVS Booster Fan train to provide adequate dose reduction.

ACTIONS With the two CRVS Boos6ter Fan trains incapable Of pressur;izig the control rooem, the capability tog pressur~ze the control room muist be rqstored within 30) days. In; thiS Cniin the Gapabii~ty to mlinimize the radiationG doseA, to personnel located in the Control Rooam.

du--rin~g and after an acc-iddent i6 Rot assured-One or both CRVS Boos6ter Fan tran maI OCONEE UNITS 1, 2, & 3 B 3.7.9-6 Amendment Nos. xxx, xxx, & xxx

AcTIONS ued()inued) be OPER-A.BLEr-in this oniton If onon o~r both CRVSBoste Fansb are simultaneously inopeable, the CompIfeio Time fo these separate Conditions is more limiting thant the 30 day Completion TmofournAtionr A

n.

if OPER CBLE the CRVS Booster Fan occat rais ln proqide some do eireducrtien. The 30 day cmpletieo Time is based en the low probability of an acident occurr:ing during the time perofd and the potential far zPaRdu ce Cls Boroster Fan train to proavidey is comebdote retdutkocretion.

81.1, B.2, and B.3 (continued)

If the unfiltered inleakage of potentially contaminated air past the ORE boundary and into the CRE can result in ORE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of ORE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE ORE boundary within 90 days.

During the period that the ORE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on ORE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed established dose limits and that CRE occupants are protected from hazardous chemicals and smoke.

For a radiological event, a preplanned mitigating action is to offset the consequences of the inoperable CRE boundary by distributing potassium iodide tablets to control room personnel. For a chemical release, the on-site hazardous chemical assessment shows that the concentrations of hazardous chemicals within the control room are acceptable during a hazardous chemical release. In addition, the ONS is located in a non-industrial area with no significant highway or river traffic. The off-site hazardous chemical assessment concludes that there are no potential off-site fixed sources of toxic gas that adversely affect control room habitability.

In the unlikely event that a station fire was to generate significant smoke that entered the outside air intake of the Control Room, a contingency action is to have the essential operators in the affected Control Room don Self-contained Breathing Apparatus (SCBA). An operations management procedure requires that all fire brigade and control room personnel, including oversight personnel maintain training and qualification for using a self-contained breathing apparatus (SCBA).

In addition, the Standby Shutdown Facility (SSF) provides a secondary alternate and independent means to achieve and maintain a hot shutdown condition for scenarios in which the Control Room is unavailable or equipment it controls is OCONEE UNITS 1, 2, & 3 B 3.7.9-7 Amendment Nos. xxx, xxx-...'O, & xxx-4% I

CRVS Booster Fans B 3.7.9 BASES unavailable. The SSF was designed for safe shutdown during postulated fire, Turbine Building flooding, and physical security events. The SSF is housed in a separate structure that is physically removed from the auxiliary building and control room. The SSF has its own ventilation system that is completely independent from any of the plant ventilation systems.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability ACTIONS (continued) of a DBA occurring during this time period, and use of mitigating actions.

The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

J I II With one IN~v maossr WaR train Inopera1D1o ;OF reAsons eer mhan C*ondifion A, action must be taken to reto.-e the*,pr tr-aiR to4 QPE=R-A8I=B status within 72 hu-rs. in this Condition, the remaining OPERA1BLE t-he ConAtroal Roonm. The 7-2 hour Completion Timoe is based on the low probability Of A an.acciden-t ocurring during this time peFiod, a the remaining train to provide some dose reducation.

C.1 and C.2 In MODE 1. 2. 3, or 4, if the inoperable CRVS Booster Fan train or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion 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.

D.1 and D.2 In MODE 5 or 6. or durina movement of recentlv irradiated fuel assemblies, if the inoperable CRVS Booster Fan train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CRVS Booster Fan train(s) must be placed in the emergency mode. This action ensures that the remaining train is OCONEE UNITS 1, 2, & 3 358360, & xxx 369 B 3.7.9-8 Amendment Nos. xxx, xxx

CRVS Booster Fans B 3.7.9 BASES OPERABLE, and that any active failure will be readily detected. An alternative to Required Action D.1 is to immediately suspend activities (GORtinued*that could release radioactivity that miqht require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.4.-

If the inoperable CRVS Booster Fan trains, cannot bo res~tored to OPEr=ABL R tatus-within the required Completion Time, the unit must be placcd in a MODE In which ILt_

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o ACTIONS E. 1 In MODE 5 or 6 or durinq movement of recently irradiated fuel assemblies, when two CRVS Booster Fan trains are inoperable, or with one or more CRVS Booster Fan trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that miqht require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

ACTIONS F. 1 (continued)

If both CRVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e.. Condition B). the CRVS may not be caoable of oerformina the intended function and the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.E-(GORti~ed)

During movement of recently irradiated fuel assemblies, when one Or more CRVS trains are inoperable, action mus.t be taken immediately to suspend activities that could release radioactiVity that might require isolation of the contro! room. This p~aces the Unit ina conRdition that mininmizes the accident risk. This, dosntpeud the movyement of fuel to a safe potsition.

OCONEE UNITS 1, 2, & 3 5.8O6,

& xxx 3g B 3.7.9-9 Amendment Nos. xxx, xxx

CRVS Booster Fans B 3.7.9 BASES SURVEILLANCE REQUIREMENTS SR 3.7.9.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month adequately checks this system. The trains need only be operated for

> 15 minutes and all damoers verified to be OPERABLE to demonstrate the function of the system. This test includes an external visual inspection of the CRVS Booster Fan trains. The surveillance frequency is based on the known reliability of the equipment and will be managed in accordance with the Surveillance Freauencv Control Proaram (Ref. 9V.92 days adequately chocks this system. The traiAS need enly be operated forF >- one hour and all damper-s Yerified to be GPERABLE to demon9Atrat the func-tion of the system. This. test includes an external visual inspection o-f t-he C-RVS-Booste0Kr Fan t-rainsD. The 92 day FrFequny bnased en the known reliability of the eqiuipment.

SR 3.7.9.2 This SR verifies that the required CRVS Booster Fan train testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRVS Booster Fan train filter test frequencies are in accordance with Regulatory Guide 1.52 (Ref. 54). The VFTP includes testing HEPA filter performance and carbon absorber efficiency. Specific OCONEE UNITS 1, 2, & 3 358360, & xxx 3%.

B 3.7.9-10 Amendment Nos. xxx, xxx

CRVS Booster Fans B 3.7.9 BASES

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

SR 3.7.9.3 This SR verifies that each CRVS Booster Fan train can be manually started and automatic actions occur. The surveillance frequency is based on industry operatingq experience and is consistent with the typical refuelingq cycle and will be managed in accordance with the Surveillance Frequency Control Program (Ref. 9).

SR 3.7.9.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

SURVEILLANCE The CRE is considered habitable when the radiological dose to CRE REQUIREMENTS occupants calculated in the licensing basis analyses of DBA (continued) consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakaqe is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensinq basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.7.2.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitiqating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 8).

Options for restoring the CRE boundary to OPERABLE status include chanqinq the licensing basis DBA consequence analysis, repairinq the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

SR 3.7.9.5 OCONEE UNITS 1, 2, & 3 B 3.7.9-11 Amendment Nos. xxx, xxx 3SR36, & xxx 3-

CRVS Booster Fans B 3.7.9 BASES This SR verifies the CRVS Booster Fan trains can supply the CRE with outside air to meet the design requirement. The Frequency of is consistent with industry practice and other filtration SRs, and will be managed in accordance with the Surveillance Frequency Control Program (Ref. 9).

OCONEE UNITS 1, 2, & 3 368369, & xxx 359 B 3.7.9-12 Amendment Nos. xxx, xxx

CRVS Booster Fans B 3.7.9 BASES SR 3.

7.9 REFERENCES

1. UFSAR, Section 9.4.

-2.

UFSAR, Chapter 15.

3. Letter from W. R. McCollum, Jr. to US Nuclear Regulatory Commission dated December 9, 2003 "Response to NRC Generic Letter 2003-01. Control Room Habitabilitv."

4. 10 CFR 50.36.

5._=

-4.

Regulatory Guide 1.52, Rev. 2, March 1978.

6. Re-gulatory Guide 1.196.

7.

NEI 99-03, "Control Room Habitability Assessment," June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."

4-9.

Letter from John Stang- (NRC) to Preston Gillespie (Duke Energy), Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments regarding Adoption of Technical Specification Task Force (TSTF)-425 Revision 3, "Relocate Surveillance Frequencies to Licensee Control: Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b," dated March 21, 2011.

10. OSC-7734, Rev. 2.

OCONEE UNITS 1, 2, & 3 3*8366,

& xxx &%

B 3.7.9-13 Amendment Nos. xxx, xxx

ATTACHMENT 2 REVISED TECHNICAL SPECIFICATION AND BASES PAGES Remove page Insert page 3.7.9-1 3.7.9-1 3.7.9-2 3.7.9-2 3.7.9-3 5.0-22 5.0-22 5.0-23 5.0-23 5.0-24 5.0-24 5.0-25 5.0-25 5.0-26 5.0-26 5.0-27 5.0-27 5.0-28 5.0-28 B 3.7.9-1 B 3.7.9-1 B 3.7.9-2 B 3.7.9-2 B 3.7.9-3 B 3.7.9-3 B 3.7.9-4 B 3.7.9-4 B 3.7.9-5 B 3.7.9-5 B 3.7.9-6 B 3.7.9-7 B 3.7.9-8

CRVS Booster Fans 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Ventilation System (CRVS) Booster Fans LCO 3.7.9 Two CRVS Booster Fan trains shall be OPERABLE.

NOTE............

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY:

MODES 1, 2, 3, 4, 5 and 6, During movement of recently irradiated fuel assemblies for any unit.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One CRVS Booster Fan A.1 Restore CRVS Booster 7 days train inoperable for Fan train to OPERABLE reasons other than status.

Condition B.

B.

One or more CRVS B.1 Initiate action to Immediately Booster Fan trains implement mitigating inoperable due to actions inoperable CRE boundary in MODE 1, 2, AND 3, or4.

B.2 Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

OCONEE UNITS 1, 2, & 3 3.7.9-1 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans 3.7.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Actions and C.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B AND not met in MODE 1, 2, 3, or 4.

C.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D.

Required Actions and D.1 Place OPERABLE Immediately associated Completion CRVS Booster Fan train Time of Condition A not in emergency mode met in MODE 5 or 6, or during movement of OR recently irradiated fuel assemblies.

D.2 Suspend movement of Immediately recently irradiated fuel assemblies.

E.

Two CRVS Booster Fan E.1 Suspend movement of Immediately trains inoperable in recently irradiated fuel MODE 5 or 6, or during assemblies.

movement of recently irradiated fuel assemblies.

OR One or more CRVS Booster Fan trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of recently irradiated fuel assemblies.

(continued)

OCONEE UNITS 1, 2, & 3 3.7.9-2 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans 3.7.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Two CRVS Booster Fan F.1 Enter LCO 3.0.3.

Immediately trains inoperable in MODE 1, 2, 3, or4 for reasons other than Condition B.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRVS Booster Fan train for In accordance with the

_ 15 minutes.

Surveillance Frequency Control Program SR 3.7.9.2 Perform required CRVS Booster Fan train In accordance with the filter testing in accordance with the Ventilation VFTP Filter Testing Program (VFTP).

SR 3.7,9.3 Manually start each CRVS Booster Fan Train In accordance with the and verify automatic actions.

Surveillance Frequency Control Program SR 3.7.9.4 Perform required CRE unfiltered air inleakage In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program.

Habitability Program SR 3.7.9.5 Verify the system makeup flow rate is _> 1215 In accordance with the and < 1485 cfm when supplying the control Surveillance Frequency room with outside air.

Control Program OCONEE UNITS 1, 2, & 3 3.7.9-3 Amendment Nos. xxx, xxx, & xxx I

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Battery Discharge Testing Program (continued)

b.

If battery capacity is determined to be < 80% of the manufacturer's rating an OPERABILITY evaluation shall be initiated immediately and completed within the guidelines of the Oconee OPERABILITY program. If the OPERABILITY evaluation determines the battery OPERABLE, battery capacity shall be restored to >_ 80% of the manufacturer's rating within a time frame commensurate with the safety significance of the issue.

Otherwise, the battery shall be declared inoperable and the applicable Condition of Specification 3.8.3 shall be entered.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Battery Discharge Testing Program surveillance frequencies.

5.5.21 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.22 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Ventilation System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

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

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Control Room Envelope Habitability Progqram (continued)

The program shall include the following elements:

a.

The definition of the CRE and the CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CRVS, operating at the flow rate required by the VFTP, at a frequency in accordance with the Surveillance Frequency Control Program on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

OCONEE UNITS 1, 2, & 3 5.0-23 Amendment Nos. xxx, xxx, & xxx

Reporting Requirements 5.0 ADMINISTRATIVE CONTROLS 5.6 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Deleted 5.6.2 Annual Radiological Environmental Operatingq Report

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year.

The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

OCONEE UNITS 1, 2, & 3 5.0-24 Amendment Nos. xxx, xxx, & xxx

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.3 Radioactive Effluent Release Report NOTE A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit in the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.

The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR part 50, Appendix I,Section IV.B.1.

5.6.4 Deleted 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

Core operating limits shall be established, determined and issued in accordance with the following:

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

Shutdown Margin limit for Specification 3.1.1;

2.

Moderator Temperature Coefficient limit for Specification 3.1.3;

3.

Physical Position, Sequence and Overlap limits for Specification 3.2.1 Rod Insertion Limits;

4.

AXIAL POWER IMBALANCE operating limits for Specification 3.2.2;

5.

QUADRANT POWER TILT (QPT) limits for Specification 3.2.3; OCONEE UNITS 1, 2, & 3 5.0-25 Amendment Nos. xxx, xxx, & xxx

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

6.

Nuclear Overpower Flux/Flow/Imbalance and RCS Variable Low Pressure allowable value limits for Specification 3.3.1;

7.

RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits for Specification 3.4.1

8.

Core Flood Tanks Boron concentration limits for Specification 3.5.1;

9.

Borated Water Storage Tank Boron concentration limits for Specification 3.5.4;

10.

Spent Fuel Pool Boron concentration limits for Specification 3.7.12;

11.

RCS and Transfer Canal boron concentration limits for Specification 3.9.1; and

12.

AXIAL POWER IMBALANCE protective limits and RCS Variable Low Pressure protective limits for Specification 2.1.1.

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

(1)

DPC-NE-1002-A, Reload Design Methodology II; (2)

NFS-1001-A, Reload Design Methodology; (3)

DPC-NE-2003-P-A, Oconee Nuclear Station Core Thermal Hydraulic Methodology Using VIPRE-01; (4)

DPC-NE-1004-A, Nuclear Design Methodology Using CASMO-3/SIMULATE-3P; (5)

DPC-NE-2008-P-A, Fuel Mechanical Reload Analysis Methodology Using TACO3; (6)

BAW-10192-P-A, BWNT LOCA - BWNT Loss of Coolant Accident Evaluation Model for Once-Through Steam Generator Plants; OCONEE UNITS 1, 2, & 3 5.0-26 Amendment Nos. xxx, xxx, & xxx

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

(7)

DPC-NE-3000-P-A, Thermal Hydraulic Transient Analysis Methodology; (8)

DPC-NE-2005-P-A, Thermal Hydraulic Statistical Core Design Methodology; (9)

DPC-NE-3005-P-A, UFSAR Chapter 15 Transient Analysis Methodology; and (10)

BAW-10227-P-A, Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel.

(11)

BAW-10164P-A, RELAP 5/MOD2-B&W-An Advanced Computer Program for Light Water Reactor LOCA and non-LOCA Transient Analysis The COLR will contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (i.e.,

report number, title, revision number, report date or NRC SER date, and any supplements).

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitorinq (PAM) and Main Feeder Bus Monitor Panel (MFPMP)

Report When a report is required by Condition B or G of LCO 3.3.8, "Post Accident Monitoring (PAM) Instrumentation" or Condition D of LCO 3.3.23, "Main Feeder Bus Monitor Panel," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring (PAM only),

the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Any abnormal degradation of the containment structure detected during the tests required by the Pre-stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a OCONEE UNITS 1, 2, & 3 5.0-27 Amendment Nos. xxx, xxx, & xxx

Reporting Requirements 5.6 5.6 Reporting Requirements description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken.

5.6.8 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 5.5.10, Steam Generator (SG) Program. The report shall include:

a.

The scope of inspections performed on each SG,

b.

Active degradation mechanisms found,

c.

Nondestructive examination techniques utilized for each degradation mechanism,

d.

Location, orientation (if linear), and measured sizes (if available) of service induced indications,

e.

Number of tubes plugged during the inspection outage for each active degradation mechanism,

f.

Total number and percentage of tubes plugged to date,

g.

The results of condition monitoring, including the results of tube pulls and in-situ testing, and

h. The effective plugging percentage for all plugging in each SG.

OCONEE UNITS 1, 2, & 3 5.0-28 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 B 3.7 PLANT SYSTEMS B 3.7.9 Control Room Ventilation System (CRVS) Booster Fans BASES BACKGROUND The CRVS Booster Fan trains provide a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CRVS consists of two redundant Booster Fan trains that supply filtered outdoor air to the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air (Ref 1). Each CRVS Booster Fan train consists of a filter assembly, booster fan, ducting and dampers that supply filtered air to the control room. Each filter train consists of a pre-filter, a high efficiency particulate air (HEPA) filter, a charcoal filter for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. The Unit 1 & 2 CRE encompasses the control room, operator aid computer room, control room offices, restroom operator kitchen, and the technical support center. The Unit 3 CRE encompasses the control room, control room office, operator aid computer room, restroom, operator kitchen, cable room vestibule, and the operations support center. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

The CRVS Booster Fan trains are an emergency system. Upon receipt of a radiation alarm from the Control Room air radiation monitor; the CRVS Booster Fan trains can be started manually to minimize unfiltered air from entering the control room. Upon starting the fans, dampers are automatically positioned to isolate the control room. The pre-filters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the HEPA and carbon filters.

OCONEE UNITS 1, 2, & 3 B 3.7.9-1 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans B 3.7.9 BASES BACKGROUND Either CRVS Booster Fan train can pressurize the Control Room to (continued) minimize infiltration of unfiltered air. The CRVS operation is discussed in the UFSAR, Section 9.4 (Ref. 1).

The CRVS Booster Fan trains are designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a DBA, without exceeding a 5 rem total effective dose equivalent (TEDE).

APPLICABLE The CRVS Booster Fan train components are arranged in two ventilation SAFETY ANALYSIS trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CRVS provides airborne radiological protection for the CRE occupants as demonstrated by the CRE occupant dose analysis for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2). Dose calculations (Ref. 10) utilize the flowrate for one train and the maximum allowable unfiltered leakage to evaluate CRE occupant radiological protection.

The CRVS Booster Fan trains provide protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 3). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the standby shutdown facility (Ref. 3).

The CRVS Booster Fan trains satisfy Criterion 3 of 10 CFR 50.36 (Ref. 4).

LCO Two CRVS trains are required to be OPERABLE. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

Each CRVS Booster Fan train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CRVS Booster Fan train is considered OPERABLE when the associated:

a.

Booster Fan is OPERABLE;

b.

HEPA filter and carbon absorber are not excessively restricting flow, and are capable of performing their filtration functions; and OCONEE UNITS 1, 2, & 3 B 3.7.9-2 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans B 3.7.9 BASES LCO

c.

Ductwork, valves, and dampers are OPERABLE, and control room (continued) unfiltered inleakage can be maintained within limits.

In order for the CRVS Booster Fan trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of recently irradiated fuel assemblies, the CRVS Booster Fan trains must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of recently irradiated fuel assemblies by any unit, the CRVS Booster Fan trains must be OPERABLE to cope with a release due to a fuel handling accident involving handling recently irradiated fuel. Due to radioactive decay, CRVS is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ).

ACTIONS A.1 With one CRVS Booster Fan train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period and the potential for the OPERABLE CRVS Booster Fan train to provide adequate dose reduction.

OCONEE UNITS 1, 2, & 3 B 3.7.9-3 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans B 3.7.9 BASES ACTIONS B.1, B.2, and B.3 (continued)

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed established dose limits and that CRE occupants are protected from hazardous chemicals and smoke.

For a radiological event, a preplanned mitigating action is to offset the consequences of the inoperable CRE boundary by distributing potassium iodide tablets to control room personnel. For a chemical release, the on-site hazardous chemical assessment shows that the concentrations of hazardous chemicals within the control room are acceptable during a hazardous chemical release. In addition, the ONS is located in a non-industrial area with no significant highway or river traffic. The off-site hazardous chemical assessment concludes that there are no potential off-site fixed sources of toxic gas that adversely affect control room habitability.

In the unlikely event that a station fire was to generate significant smoke that entered the outside air intake of the Control Room, a contingency action is to have the essential operators in the affected Control Room don Self-contained Breathing Apparatus (SCBA). An operations management procedure requires that all fire brigade and control room personnel, including oversight personnel maintain training and qualification for using a self-contained breathing apparatus (SCBA).

In addition, the Standby Shutdown Facility (SSF) provides a secondary alternate and independent means to achieve and maintain a hot shutdown condition for scenarios in which the Control Room is unavailable or equipment it controls is unavailable. The SSF was designed for safe shutdown during postulated fire, Turbine Building flooding, and physical security events. The SSF is housed in a separate structure that is physically removed from the auxiliary building and control room. The SSF has its own ventilation system that is completely independent from any of the plant ventilation systems.

OCONEE UNITS 1, 2, & 3 B 3.7.9-4 Amendment Nos. xxx, xxx, & xxx I

CRVS Booster Fans B 3.7.9 BASES ACTIONS (continued)

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and use of mitigating actions.

The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CRVS Booster Fan train or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion 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.

D.1 and D.2 In MODE 5 or 6, or during movement of recently irradiated fuel assemblies, if the inoperable CRVS Booster Fan train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CRVS Booster Fan train(s) must be placed in the emergency mode. This action ensures that the remaining train is OPERABLE, and that any active failure will be readily detected. An alternative to Required Action D. 1 is to immediately suspend activities that could release radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

E. 1 In MODE 5 or 6 or during movement of recently irradiated fuel assemblies, when two CRVS Booster Fan trains are inoperable, or with one or more CRVS Booster Fan trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

OCONEE UNITS 1, 2, & 3 B 3.7.9-5 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES ACTIONS F.1 (continued)

If both CRVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), the CRVS may not be capable of performing the intended function and the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month adequately checks this system. The trains need only be operated for

>_ 15 minutes and all dampers verified to be OPERABLE to demonstrate the function of the system. This test includes an external visual inspection of the CRVS Booster Fan trains. The surveillance frequency is based on the known reliability of the equipment and will be managed in accordance with the Surveillance Frequency Control Program (Ref. 9).

SR 3.7.9.2 This SR verifies that the required CRVS Booster Fan train testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRVS Booster Fan train filter test frequencies are in accordance with Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance and carbon absorber efficiency. Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.9.3 This SR verifies that each CRVS Booster Fan train can be manually started and automatic actions occur. The surveillance frequency is based on industry operating experience and is consistent with the typical refueling cycle and will be managed in accordance with the Surveillance Frequency Control Program (Ref. 9).

SR 3.7.9.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

OCONEE UNITS 1, 2, & 3 B 3.7.9-6 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued)

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.7.2.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 8).

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

SR 3.7.9.5 This SR verifies the CRVS Booster Fan trains can supply the CRE with outside air to meet the design requirement. The Frequency of is consistent with industry practice and other filtration SRs, and will be managed in accordance with the Surveillance Frequency Control Program (Ref. 9).

OCONEE UNITS 1, 2, & 3 B 3.7.9-7 Amendment Nos. xxx, xxx, & xxx

CRVS Booster Fans B 3.7.9 BASES REFERENCES

1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

3. Letter from W. R. McCollum, Jr. to US Nuclear Regulatory Commission dated December 9, 2003 "Response to NRC Generic Letter 2003-01, Control Room Habitability."

4. 10 CFR 50.36.

5. Regulatory Guide 1.52, Rev. 2, March 1978.

6. Regulatory Guide 1.196.

7. NEI 99-03, "Control Room Habitability Assessment," June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."

9. Letter from John Stang (NRC) to Preston Gillespie (Duke Energy),

Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments regarding Adoption of Technical Specification Task Force (TSTF)-425 Revision 3, "Relocate Surveillance Frequencies to Licensee Control; Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b," dated March 21, 2011.

10. OSC-7734, Rev. 2.

OCONEE UNITS 1, 2, & 3 B 3.7.9-8 Amendment Nos. xxx, xxx, & xxx

v t e Letter Sequence Request
TAC:ME7505, Control Room Habitability, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation (Withdrawn, Closed)
Initiation Request, Request Acceptance... Administration Questions Answers Results Withdrawal Other:
MONTHYEAR2011-12-09 [Table View]

ML11299A017

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Subject:

Subject:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

7.9 REFERENCES

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