RA-20-0011, Application for Technical Specifications Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

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Application for Technical Specifications Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process
ML20041F551
Person / Time
Site: Oconee, Harris  Duke Energy icon.png
Issue date: 02/06/2020
From: Snider S
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0011
Download: ML20041F551 (71)


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U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT OF THE PROPOSED CHANGE OCONEE NUCLEAR STATION, UNIT NOS. 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, AND DPR-55 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63 6 PAGES (INCLUDING COVER)

U.S. Nuclear Regulatory Commission Page 1 of 5 Serial RA-20-0011 Description and Assessment of the Proposed Change Application for Technical Specifications Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

1.0 DESCRIPTION

The proposed amendment would modify the Oconee Nuclear Station (ONS), Unit Nos. 1, 2, and 3, and Shearon Harris Nuclear Power Plant (HNP), Unit 1, Technical Specifications (TS) requirements for mode change limitations in limiting condition for operation (LCO) 3.0.4 and surveillance requirement (SR) 3.0.4 for ONS and SR 4.0.4 for HNP. The proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-359, Revision 9, Increase Flexibility in Mode Restraints (ADAMS Accession No. ML031190607),

which is the equivalent of TSTF-359, Revision 8 (ADAMS Accession No. ML023430260), as modified by the notice in the Federal Register published April 4, 2003 (68 FR 16579). That Federal Register notice announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).

The tables at the end of this attachment list the affected TS and TS Bases for each site and provides a brief description of the changes.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Duke Energy (Duke Energy Progress, LLC and Duke Energy Carolinas, LLC) has reviewed the safety evaluation dated April 4, 2003 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-359 Revision 8. Duke Energy has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to ONS and HNP, and justify this amendment for the incorporation of the changes to the ONS and HNP TS.

2.2 Optional Changes and Variations Duke Energy is proposing the following variations from the TS changes described in the modified TSTF-359 Revision 8 and the NRC staffs model safety evaluation dated April 4, 2003.

a. The ONS and HNP TS utilize different numbering and titles than NUREG-1430, Standard Technical Specifications - Babcock and Wilcox Plants (ADAMS Accession No. ML12100A177), and NUREG-1431, Standard Technical Specifications - Westinghouse Plants (ADAMS Accession No. ML12100A222),

respectively, on which TSTF-359 was based. Additionally, the ONS and HNP TS do not contain all of the TS that were revised by TSTF-359. These differences are administrative and do not affect the applicability of TSTF-359 to the ONS and HNP TS.

b. HNP has not converted to the Improved Technical Specifications (ITS, NUREG-1431). As a result, the HNP individual SRs do not stipulate the specific time frames and conditions necessary for meeting the SRs to allow entry into the mode or

U.S. Nuclear Regulatory Commission Page 2 of 5 Serial RA-20-0011 condition of applicability without having performed the SR. Consequently, the existing exceptions to SR 4.0.4 will be retained in the HNP TS, and the proposed Bases for SR 4.0.4 will not include the paragraph below that is included in TSTF-359 for the Bases of ITS SR 3.0.4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCOs Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

c. TSTF-359 and the model safety evaluation refer to Regulatory Guide (RG) 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. However, RG 1.182 was withdrawn in November 2012 after being determined to be redundant due to the inclusion of its information in RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. As such, the proposed bases for ONS and HNP LCO 3.0.4 refer to RG 1.160 rather than RG 1.182, an administrative variation that does not affect the applicability of TSTF-359 to the ONS and HNP TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Analysis 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 ONS and HNP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

The proposed variations provided in Section 2.2 of this submittal do not impact the applicability of the proposed NSHCD.

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003, for this TS improvement, plant-specific verifications were performed as follows:

1. Duke Energy has established TS Bases for LCO 3.0.4 and SR 3.0.4 (SR 4.0.4 for HNP) which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 (SR 4.0.4 for HNP) is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before

U.S. Nuclear Regulatory Commission Page 3 of 5 Serial RA-20-0011 entering an associated mode or other specified condition in the TS Applicability.

2. The modification also includes changes to the bases for LCO 3.0.4 and SR 3.0.4 (SR 4.0.4 for HNP) that provide details on how to implement the new requirements. The bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The bases changes describe in detail how:
a. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and
c. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g.,

Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient), though it may be applied to other Specifications based on NRC plant-specific approval.

3. The bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160. Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions.
4. In addition, the bases state that upon entry into a Mode or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry in to the applicable ACTIONS until the condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the TS. The bases also state that SR 3.0.4 (SR 4.0.4 for HNP) does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3 (SR 4.0.3 for HNP). Finally, Duke Energy has a bases control program consistent with Section 5.5 of the ITS, and the equivalent of ITS SR 3.0.1 and associated bases.

4.0 ENVIRONMENTAL EVALUATION Duke Energy has reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003 as part of the CLIIP. Duke Energy has concluded that the staff's findings presented in that evaluation are applicable to Oconee Nuclear Station, Unit Nos. 1, 2, and 3 and Shearon Harris Nuclear Power Plant, Unit 1, and the evaluation is hereby incorporated by reference for this application.

U.S. Nuclear Regulatory Commission Page 4 of 5 Serial RA-20-0011 Table of Affected HNP Technical Specifications and Brief Description of Changes Technical Specification No.

Description of the Change LCO 3.0.4 Delete current LCO 3.0.4 and replace with TSTF-359 requirements.

SR 4.0.4 Delete current SR 4.0.4 and replace with TSTF-359 requirements.

Table 3.3-3 Delete

  • from Action 15a for Functional Unit 9, Loss-of-Offsite Power, and corresponding Note, which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.3.3.5 Delete Action d, which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.3.3.6 Delete Action f, which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.4.4 Delete Action d, which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.4.8 Delete from Action a the exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions. Add a new note that LCO 3.0.4.c is applicable to Dose Equivalent I-131, consistent with TSTF-359.

LCO 3.4.9.4 Delete Action e, which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions. Add new note that LCO 3.0.4.b is not applicable when entering Mode 4, consistent with TSTF-359.

LCO 3.5.3 Add a new note that LCO 3.0.4.b is not applicable to ECCS high head subsystem, consistent with TSTF-359.

LCO 3.7.1.2 Add a new note that LCO 3.0.4.b is not applicable, consistent with TSTF-359.

LCO 3.8.1.1 Add a new note that LCO 3.0.4.b is not applicable to diesel generators, consistent with TSTF-359.

Bases for LCO 3.0.4 Revise bases to adopt TSTF-359 bases for ITS LCO 3.0.4.

Bases for SR 4.0.4 Revise bases to adopt TSTF-359 bases for ITS SR 3.0.4.

Bases for LCO 3.4.8 Add discussion related to LCO 3.0.4.c allowance consistent with TSTF-359.

Bases for LCO 3.4.9.4 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

Bases for LCO 3.5.3 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

Bases for LCO 3.7.1.2 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

Bases for LCO 3.8.1.1 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

U.S. Nuclear Regulatory Commission Page 5 of 5 Serial RA-20-0011 Table of Affected ONS Technical Specifications and Brief Description of Changes Technical Specification No.

Description of the Change LCO 3.0.4 Delete current LCO 3.0.4 and replace with TSTF-359 requirements.

SR 3.0.4 Delete current SR 3.0.4 and replace with TSTF-359 requirements.

LCO 3.3.8 Delete Note 1 which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.4.11 Delete from Actions A and B the exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions. Adjust notes in Actions A and B to reflect that LCO 3.0.4.c is applicable to Dose Equivalent I-131 and Dose Equivalent Xe-133, consistent with TSTF-359.

LCO 3.4.15 Delete Note which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.5.3 Add a new note that LCO 3.0.4.b is not applicable, consistent with TSTF-359.

LCO 3.7.5 Add a new note that LCO 3.0.4.b is not applicable when entering Mode 1, consistent with TSTF-359.

LCO 3.7.10 Delete Note which provides an exception to LCO 3.0.4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.8.1 Delete Note which provides an exception to LCO 3.0.4 when both standby buses are energized to comply with Required Actions. TSTF-359 removes existing LCO 3.0.4 exceptions. Add a new note that LCO 3.0.4.b is not applicable to KHUs, consistent with TSTF-359.

Bases for LCO 3.0.4 Revise bases to adopt TSTF-359 bases for LCO 3.0.4.

Bases for SR 3.0.4 Revise bases to adopt TSTF-359 bases for SR 3.0.4.

Bases for LCO 3.3.8 Remove content related to existing LCO 3.0.4 exception, consistent with TSTF-359.

Bases for LCO 3.4.11 Remove content related to existing LCO 3.0.4 exception and add discussion related to LCO 3.0.4.c allowance, consistent with TSTF-359.

Bases for LCO 3.4.15 Remove content related to existing LCO 3.0.4 exception, consistent with TSTF-359.

Bases for LCO 3.5.3 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

Bases for LCO 3.7.5 Add discussion concerning the application of LCO 3.0.4.b, consistent with TSTF-359.

Bases for LCO 3.7.10 Remove content related to existing LCO 3.0.4 exception, consistent with TSTF-359.

Bases for LCO 3.8.1 Remove content related to existing LCO 3.0.4 exception and add discussion concerning application of LCO 3.0.4.b, consistent with TSTF-359.

U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES FOR HNP (MARK-UP)

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63 15 PAGES (INCLUDING COVER)

SHEARON HARRIS - UNIT 1 3/4 0-1 Amendment No. 155 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required unless otherwise noted in the ACTION statement.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
c. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation.

Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements or that are part of a shutdown of the unit. Exceptions to these requirements are stated in the individual specifications.

3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to 3.0.1 above for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.6 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

Replace with

<INSERT 1>

< INSERT 1 >

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SHEARON HARRIS - UNIT 1 3/4 0-2 Amendment No. 162 APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued)

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation, unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the surveillance or between performances of the surveillance, shall be failure to meet the LCO. Failure to perform a surveillance within the specified surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

4.0.3 If it is discovered that a surveillance was not performed within its specified surveillance interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the surveillance. The delay period is only applicable when there is reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION requirements must be met.

When the surveillance is performed within the delay period and the surveillance criteria are not met, the LCO must immediately be declared not met, and the applicable ACTION requirements must be met.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation has been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Deleted Replace with

<INSERT 2>

< INSERT 2 >

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified frequency, except as provided by SR 4.0.3.

When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT

8.

Containment Spray Switch-over to Containment Sump (Continued)

9.
b.

RWST--Low Low Coincident With Containment Spray Loss-of-Offsite Power

a.

6.9 kV Emergency Bus--

Undervoltage Primary

b.

6.9 kV Emergency Bus--

Undervoltage Secondary

10.

Engineered Safety Features Actuation System Interlocks

a.
b.

C.

d.

Pressurizer Pressure.

P-11 Not P-11 Low-Low Tavg

P-14 SHEARON HARRIS - UNIT 1 TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION See Item 7.b. above for all RWST--Low Low initiating functions and requirements.

See Item 2 above for all Containment Spray initiating functions and requirements.

3/bus 3/bus 3

3 3

2 See Item 5. b.

requirements.

2/bus 2/bus 2

2 2

2 above for all 3/4 3-25 2/bus 2/bus 2

2 2

2

1. 2. 3, 4
1. 2, 3, 4
1. 2. 3
1. 2. 3
1. 2. 3
1. 2. 3 15a)...

15~

20 20 20 22 P-14 initiating functions and Amendment 1-9 I

TABLE 3.3-3 (Cont inued)

TABLE NOTATIONS

  • The provisions of Specification 3.0.4 are not applicable.
  1. Trip function may be blocked 1n this MODE below the P-11 (Pressurizer Pressure Interlock) Setpoint.

refer to Specification 3.9.9.

      • Trip function automatically blocked above P-11 and may be blocked below P-11 when Safety Injection on low steam line pressure is not blocked.

ACTION STATEMENTS ACTION 14 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement. restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; however. one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.

provided the other channel is OPERABLE.

ACTION 15 - With the number of OPERABLE channels one less than the Total Number of Channels. operation may proceed until performance of the next required CHANNEL OPERATIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACTION 15a - With the number of OPERABLE channels one less than the Total Number of Channels. operation may proceed provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

With less than the minimum channels OPERABLE. operation may proceed provided the minimum number of channels is restored within one hour. otherwise declare the affected diesel generator inoperable.

When performing surveillance testing of either primary or secondary undervoltage relays, the redundant emergency bus and associated primary and secondary relays shall be OPERABLE.

ACTION 16 - With the number of OPERABLE channels one less than the Total Number of Channels. operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and the Minimum Channels OPERABLE requirement is met.

One additional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.

ACTION 17 - With less than the Minimum Channel s OPERABLE requirement.

operation may continue provided the Containment Purge Makeup and Exhaust Isolation valves are maintained closed while in MODES 1.

2. 3 and 4 (refer to Specification 3.6.1.7).

For MODE 6. refer to Specification 3.9.4.

ACTION 18 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement. restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SHEARON HARRIS - UNIT 1 3/4 3-26 Amendment No. +G-l

SHEARON HARRIS - UNIT 1 3/4 3-63 Amendment No. 154 INSTRUMENTATION REMOTE SHUTDOWN SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.5.a The Remote Shutdown System monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE.

3.3.3.5.b All transfer switches, Auxiliary Control Panel Controls and Auxiliary Transfer Panel Controls for the OPERABILITY of those components required by the SHNPP Safe Shutdown Analysis to (1) remove decay heat via auxiliary feedwater flow and steam generator power-operated relief valve flow from steam generators A and B, (2) control RCS inventory through the normal charging flow path, (3) control RCS pressure, (4) control reactivity, and (5) remove decay heat via the RHR system shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a.

With the number of OPERABLE remote shutdown monitoring channels less than the Minimum Channels OPERABLE as required by Table 3.3-9, restore the inoperable channel(s) to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With the number of OPERABLE remote shutdown monitoring channels less than the Total Number of Channels required by Table 3.3-9, restore the inoperable channels to OPERABLE status within 60 days or submit a Special Report in accordance with Specification 6.9.2 within 14 additional days.

c.

With one or more inoperable Remote Shutdown System transfer switches, power, or control circuits required by 3.3.3.5.b, restore the inoperable switch(s)/circuit(s) to OPERABLE status within 7 days, or be in HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.5.1 Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6.

4.3.3.5.2 Each Remote Shutdown System transfer switch, power and control circuit and control switch required by 3.3.3.5.b, shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program.

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION least HOT STANDBY in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

~

The provisioAs of SpecificatioA 3.0.4 are Aot applicable.

The alternate method shall be a check of safety valve piping temperatures and evaluation to determine position.

The alternate method shall be the initiation of the backup method as required by Specification 6.8.4.d.

SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION at the frequencies shown in Table 4.3-7.

SHEARON HARRIS - UNIT 1 3/4 3-67 Amendment No. :HB r

REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 All power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.

APPLICABILITY:

MODES 1. 2. and 3 ACTION:

a.

With one or more PORV(s) inoperable, because of excessive seat leakage. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s): otherwise. be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With one or more PORV(s) inoperable due to causes other than excessive seat leakage. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to OPERABLE status or close the associated block valve(s) and remove power from the block valve(s). and

1.

With only one safety grade PORV OPERABLE. restore at least a total of two safety grade PORVs to OPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. or

2.

With no safety grade PORVs OPERABLE. restore at least one safety grade PORV to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and follow ACTION b.1. above. with the time requirement of that ACTION statement based on the time of initial loss of the remaining inoperable safety grade PORV or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With one or more block valve(s) inoperable. within 1 hour:

(1) restore the block valve(s) to OPERABLE status. or close the block valve(s) and remove power from the block valve(s). or close the PORV and remove power from its associated solenoid valve: and (2) apply the ACTION b.. above. as appropriate. for the isolated PORV(s).

a-:

The provisioAs of SpecificatioA 3.0.4 are Aot applicable.

SHEARON HARRIS - UNIT 1 3/4 4-11 Amendment No. 2:/-

Replace with:

LCO 3.0.4.c is applicable to DOSE EQUIVALENT I-131.

REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the reactor coolant shall be limited to:

a.

Less than or equal to 1 microCurie per gram DOSE EQUIVALENT I-131.

and

b.

Less than or equal to 100/E microCuries per gram of gross radioactivity.

APPLICABILITY :

MODES 1. 2. 3. 4. and 5.

ACTION:

MODES 1. 2 and 3°:

a.

With the specific activity of the reactor coola greater than 1 microCurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceedi 60.0 microCurie per gram DOSE EQUIVALENT I-131. be in at least OT STANDBY with T~g less than 500°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The provisioAs of SpecificatioA 3.0.4 are Aot applicable.

b.

With the specific activity of the reactor coolant greater than 100/E microCuries per gram. be in at least HOT STANDBY with Tavg less than 500°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

MODES 1. 2. 3. 4. and 5:

With the specific activity of the reactor coolant greater than 1 microcurie per gram DOSE EQUIVALENT I-131 or greater than 100/E microCuries per gram, perform the sampling and analysis requirements of Item 4.a) of Table 4.4-4 until the specific activity of the reactor coolant is restored to within its limits.

SURVEILLANCE REQUIREMENTS 4.4.8 The specific activity of the reactor coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

0 With Tavg greater than or equal to 500°F.

SHEARON HARRIS - UNIT 1 314 4-29

~.

Amendment No. +&7

ADD:


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

LCO 3.0.4.b is not applicable when entering MODE 4 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTIO LIMITING OPERATION 3.4.9.4 At least be OPERABLE:

of the following Overpressure Protection Systems shall

a.

The Rector Coolant System (RCS) depressurized with an RCS vent of great r than or equal to 2.9 square inches, or

b.

Two ower-operated relief valves (PORVs) with setpoints which do not ex eed the limits established in Figure 3.4-4.

MODE 4 when the temperature of any RCS cold leg is less than o 325°F, MODE 5 and MODE 6 with the reactor vessel head on.

a.

With one PORV inoperable in MODE 4, restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through at least a 2.9 square inch vent within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

b.

With one PORV inoperable in MODES 5 or 6, either (1) restore the inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or (2) complete depressurization and venting of the RCS through at least a 2.9 square inch vent within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

c.

With both PORVs inoperable, depressurize and vent the RCS through at least a 2.9 square inch vent within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

d.

In the event either the PORVs or the RCS vent(s) are used to m1t1gate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.

The report shall describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective action necessary to prevent recurrence.

e.

The pFovisioas of Speeifieatiea 3. 0. 4 are aet applieable, SURVEILLANCE REQUIREMENTS 4.4.9.4.1 Each PORV shall be demonstrated OPERABLE by:

a.

Performance of an ANALOG CHANNEL OPERATIONAL TEST on the PORV actua-tion channel, but excluding valve operation, within 31 days prior to Credit may only be taken for the setpoints when the RCS cold leg temperature> 90°F.

SHEARON HARRIS -

UNIT 1 3/4 4-40 Amendment No. 'J.+

ADD:


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

LCO 3.0.4.b is not applicable to ECCS high head subsystem.

EMERGENCY CORE COOLING SYSTEMS 3/4.5.3 ECCS SUBSYSTEMS - Ta"g LESS THAN 350°F LIMITING CONDITION FOR OPERATION 3.5.3 As a minimum. one ECCS subsystem comprised of the following shall be OPERABLE :

a.

One OPERABLE charging/safety injection pump,"

b.

One OPERABLE RHR heat exchanger.

c.

One OPERABLE RHR pump. and

d.

An OPERABLE flow path capable of taking suction from the refueling water storage tank upon being manually realigned and transferring suction to the containment sump during the recirculation phase of operation.

ACTION:

a.

With no ECCS subsystem OPERABLE because of the inoperability of either the charging/safety injection pump or the flow path from the refueling water storage tank. restore at least one ECCS subsystem to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

With no ECCS subsystem OPERABLE because of the inoperability of either the residual heat removal heat exchanger or RHR pump.

restore at least one ECCS subsystem to OPERABLE status or maintain the Reactor Coolant System Tavg less than 350°F by use of alternate heat removal methods.

c.

In the event the ECCS is actuated and injects water into the Reactor Coolant System. a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

The current value of the usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

A maximum of one charging/safety injection pump shall be OPERABLE whenever the temperature of one or more of the RCS cold legs is less than or equal to 325°F.

SHEARON HARRIS - UNIT 1 3/4 5-7 Amendment No. +/-9

SHEARON HARRIS - UNIT 1 3/4 7-4 Amendment No. 154 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:

a.

Two motor-driven auxiliary feedwater pumps, each capable of being powered from separate emergency buses, and

b.

One steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a.

With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to OPERABLE status within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s* or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With two auxiliary feedwater pumps inoperable, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c.

With three auxiliary feedwater pumps inoperable, immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible. (NOTE: LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status. Following restoration of one AFW train, all applicable LCOs apply based on the time the LCOs initially occurred.)


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

  • The A Train auxiliary feedwater pump is allowed to be inoperable for a total of 14 days only to allow for the implementation of design improvements on the A Train ESW pump. The 14 days will be taken one time no later than October 29, 2016. During the period in which the A Train ESW pump supply from the Auxiliary Reservoir or the Main Reservoir is not available, Normal Service Water will remain available and in service to supply the A Train ESW equipment loads until the system is ready for post maintenance testing. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Conditions described in HNP LAR submittal correspondence letter HNP-16-056.

SURVEILLANCE REQUIREMENTS 4.7.1.2.1 Each auxiliary feedwater pump shall be demonstrated OPERABLE:

a.

At the frequency specified in the Surveillance Frequency Control Program by:

1.

Demonstrating that each motor-driven pump satisfies performance requirements by either:

a)

Verifying each pump develops a differential pressure that (when temperature - compensated to 70°F) is greater than or equal to 1514 psid at a recirculation flow of greater than or equal to 50 gpm (25 KPPH),

or b)

Verifying each pump develops a differential pressure that (when temperature - compensated to 70°F) is greater than or equal to 1259 psid at a flow rate of greater than or equal to 430 gpm (215 KPPH).

ADD:


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

LCO 3.0.4.b is not applicable.

This ACTION is required to be completed regardless of when the inoperable EDG is restored to OPERABILITY.

  1. Activities that normally support testing pursuant to 4.8.1.1.2.a.4, which would render the diesel inoperable (e.g., air roll), shall not be performed for testing required by this ACTION statement.

SHEARON HARRIS - UNIT 1 3/4 8-1 Amendment No. 153 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and b.

Two separate and independent diesel generators, each with:

1.

A separate day tank containing a minimum of 1457 gallons of fuel, 2.

A separate main fuel oil storage tank containing a minimum of 100,000 gallons of fuel, and 3.

A separate fuel oil transfer pump.

c.

Automatic Load Sequencers for Train A and Train B.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a.

With one offsite circuit of 3.8.1.1.a inoperable:

1.

Perform Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and 2.

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and 3.

Verify required feature(s) powered from the OPERABLE offsite A.C. source are OPERABLE. If required feature(s) powered from the OPERABLE offsite circuit are discovered to be inoperable at any time while in this condition, restore the required feature(s) to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of inoperable required feature(s) or declare the redundant required feature(s) powered from the inoperable A.C. source as inoperable.

b.

With one diesel generator of 3.8.1.1.b inoperable:

1.

Perform Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and

  • 2.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, determine the OPERABLE diesel generator is not inoperable due to a common cause failure or perform Surveillance Requirement 4.8.1.1.2.a.4#; and ADD:


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

LCO 3.0.4.b is not applicable to diesel generators.

/\\

U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION CHANGES FOR ONS (MARK-UP)

OCONEE NUCLEAR STATION, UNIT NOS. 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, AND DPR-55 14 PAGES (INCLUDING COVER)

OCONEE UNITS 1, 2, & 3 3.0-1 Amendment Nos. 402, 404, & 403 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />;

b.

MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />; and

c.

MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Replace with

<INSERT 1>*----

LCO Applicability 3.0 3.0 LCO APPLICABILITY OCONEE UNITS 1, 2, & 3 3.0-2 Amendment Nos. 356, 358, & 357 LCO 3.0.4 Exceptions to this Specification are stated in the individual Specifications.

(continued)

LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.16, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed

< INSERT 1 >

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued)

OCONEE UNITS 1, 2, & 3 3.0-5 Amendment Nos. 356, 358, & 357 SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

Replace with

<INSERT 2>

D

< INSERT 2 >

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3.

When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.



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RCS Leakage Detection Instrumentation 3.4.15 OCONEE UNITS 1, 2, & 3 3.4.15-1 Amendment Nos. 394, 396, & 395 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a.

One containment normal sump level indication; and

b.

One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS


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

LCO 3.0.4 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Containment sump level indication inoperable.

A.1


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

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1.

AND A.2 Restore containment sump level indication to OPERABLE status.

Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 30 days (continued)

LPI 3.5.3 OCONEE UNITS 1, 2, & 3 3.5.3-1 Amendment Nos. 340, 342, & 341 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 Low Pressure Injection (LPI)

LCO 3.5.3 Two LPI trains shall be OPERABLE.


NOTES---------------------------------------------

1.

Only one LPI train is required to be OPERABLE in MODE 4.

2.

In MODE 4, an LPI train may be considered OPERABLE during alignment, when aligned or when operating for decay heat removal (DHR) if capable of being manually realigned to the LPI mode of operation.

3.

In MODES 1, 2, and 3, the LPI discharge header crossover valves inside containment shall be open.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One LPI train inoperable in MODE 1, 2, or 3.

A.1 Restore LPI train to OPERABLE status.

7 days B.

One or more LPI discharge header crossover valve(s) inside containment not open in MODE 1, 2, or 3.

B.1 Open LPI discharge header crossover valve(s) inside containment.

7 days (continued)

ADD:


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

LCO 3.0.4.b is not applicable to ECCS DHR loops.

1'

EFW System 3.7.5 OCONEE UNITS 1, 2, & 3 3.7.5-1 Amendment Nos. 300, 300, & 300 3.7 PLANT SYSTEMS 3.7.5 Emergency Feedwater (EFW) System LCO 3.7.5 The EFW System shall be OPERABLE as follows:

a.

Three EFW pumps shall be OPERABLE, and

b.

Two EFW flow paths shall be OPERABLE.


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

Only one motor driven emergency feedwater (MDEFW) pump and one EFW flow path are required to be OPERABLE in MODE 4.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One MDEFW pump inoperable in MODE 1, 2, or 3.

A.1 Restore MDEFW pump to OPERABLE status.

7 days AND 10 days from discovery of failure to meet the LCO B.

Turbine driven EFW pump inoperable in MODE 1, 2, or 3.

OR One EFW flow path inoperable in MODE 1, 2, or 3.

B.1 Restore turbine driven EFW pump and EFW flow path to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 10 days from discovery of failure to meet the LCO (continued)

ADD:


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

LCO 3.0.4.b is not applicable when entering MODE 1.

1' L

PSW system 3.7.10 OCONEE UNITS 1, 2, & 3 3.7.10-1 Amendment Nos. 386, 388, & 387 3.7 PLANT SYSTEMS 3.7.10 Protected Service Water (PSW) System LCO 3.7.10 The PSW system shall be OPERABLE


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

Not applicable to Unit(s) until startup from a refueling outage after completion of PSW modifications and after all of the PSW system equipment installed has been tested.

APPLICABILITY:

MODES 1 and 2.

ACTIONS


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

LCO 3.0.4 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. PSW system is inoperable.

A.1 Restore PSW system to OPERABLE status.

14 days B. PSW system is inoperable.

AND The Standby Shutdown Facility (SSF) is inoperable.

B.1 Restore PSW system to OPERABLE status.

7 days C. ----------------NOTE-----------------

Condition may only be entered when contingency measures have been implemented.

Required Action and associated Completion Time of Condition A or B not met.

C.1 Restore PSW system to OPERABLE status.

30 days from discovery of initial inoperability.

D. Required Action and associated Completion Time of Condition C not met.

D.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 /> (continued)

AC Sources - Operating 3.8.1 OCONEE UNITS 1, 2, & 3 3.8.1-1 Amendment Nos. 300, 300, & 300 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1

a.

The following AC electrical power sources shall be OPERABLE:

1.

Two offsite sources on separate towers connected to the 230 kV switchyard to a unit startup transformer and capable of automatically supplying power to one main feeder bus; and

2.

Two Keowee Hydro Units (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.

b.

The Keowee Reservoir level shall be t 775 feet above sea level.

c.

The zone overlap protection circuitry shall be OPERABLE when the overhead electrical disconnects for the KHU associated with the underground power path are closed.


NOTES---------------------------------------------

1.

A unit startup transformer may be shared with a unit in MODES 5 or 6.

2.

The requirements of Specification 5.5.18, "KHU Commercial Power Generation Testing Program," shall be met for commercial KHU power generation.

3.

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:

MODES 1, 2, 3, and 4.

No changes to this page.

AC Sources - Operating 3.8.1 OCONEE UNITS 1, 2, & 3 3.8.1-2 Amendment Nos. 300, 300, & 300 ACTIONS


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

LCO 3.0.4 is not applicable when both standby buses are energized to comply with Required Actions.

CONDITION REQUIRED ACTION COMPLETION TIME A.

Both required offsite sources and the overhead emergency power path inoperable due to inoperable unit startup transformer.

A.1 Perform SR 3.8.1.3.

AND A.2 Align the emergency startup bus to share another unit's startup transformer.

AND A.3.1 Restore unit startup transformer to OPERABLE status and normal startup bus alignment.

OR A.3.2 Designate one unit, sharing the startup transformer, to be shutdown.

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 previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 12 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 36 hours B.

Unit designated to be shutdown due to sharing a unit startup transformer.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours (continued)

Replace with:

LCO 3.0.4.b is not applicable to KHUs.

U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 4 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES FOR HNP (MARK-UP)

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63 13 PAGES (INCLUDING COVER)

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Replace with

<INSERT A>*---

SHEARON HARRIS - UNIT 1 B 3/4 0-2 Amendment No. 162 APPLICABILITY BASES 3.0.4 (Continued) operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a MODE change.

Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made and the ACTION requirements followed after entry into the Applicability.

For example, Specification 3.0.4 may be used when the required ACTION to be entered states that an inoperable instrument channel must be placed in the trip condition within the required time limit. Transition into a MODE or other specified condition in the Applicability may be made in accordance with Specification 3.0.4 and the channel is subsequently placed in the tripped condition within the required time limit, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent ACTION allows the OPERABLE train to placed in operation, use of Specification 3.0.4 is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.

3.0.5 This specification establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to 3.0.1 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. Specification 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. Specification 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV)

< INSERT A >

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the ACTIONS.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4 (b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Regulatory Guide 1.160 endorses the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of allowed outage times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions.

The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the allowed outage time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable ACTIONS until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 4.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 4.0.1 or SR 4.0.4 for any Surveillances that have not been performed on inoperable equipment.

However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

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< INSERT B >

SR 4.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 4.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 4.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified frequency does not result in an SR 4.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

SR 4.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 4.0.3.

The provisions of SR 4.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 4.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

ADD:

A Note permits the use of the provisions of LCO 3.0.4.c for this ACTION statement. This allowance permits entry into applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

REACTOR COOLANT SYSTEM BASES J/4 4 8 SPECIFIC ACTIVITY The lim1tat10ns on the specific ac ivity of Lhe reactor coolan ensure that the resulting 2-hour doses at the SITE BOUNDARY will no exceed an appropriately small fraction of 10 CFR Part 100 dose guideline values following as earn generator tube rup ure accident,n conJunct1on with an assumed steady-state reactor-to-secondary steam generator leakage rate of 1 gpm The values for he 1 im1 ts on specif, c activity represent l I mi ts based upon a parametn c eva l uat10n by the NRC of typi ca 1 site 1 ocat i ans. These values are conservative in that specific site parameters of t he SHEARON l~RRIS site. such as SITE BOUNDARY location and meteorological conditions. were not cons1dered in Lh1s evaluation The ACTION staLement permitting POWER OPERATION to continue for limited time periods with the reactor coolant's specific activit gr*eater han 1.0 microCune/gram DOSE EQUIVALENT 1-131. but less than 60.0 microCurie/gram DOSE EQUIVALENT I-131. accormioda es pas 1ble iod1ne sp1k1ng phenomenon which may occur following changes in THERMAL POWER. See Generic Letter 85-19 for additional information.

The sample analysis Fr determining the gross specific activity and E can exclude the rad1oiod nes because of the low reactor coolant limit of 1 0 micmCurie/gram DOSE EQU1VALENT 1 131. and because, if the limit is exceeded. the radi 10dine level 1s to be determined every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> _ If the gross specific a iv1ty level and radio1odine level in the reactor coolant were at their 1

  • its. the radioiodine contribution would be appro 1mately 1%

In a release o reactor coolant ~ilh a typical mixture of radioactivity. the actual radio1 aine contribution would probably be about 20%

The exclusion of radionuclide wi th half-lives less than 15 minutes f rom these determinations has been m e for several reasons.

The first cons1derat1on 1s the difficulty to 1denti t short-lived rad1onuclides 1n a sample that requires a s1gn1hcant time to lect. transport. and analyze.

The second consideration 1s the predict le delay Lime between the postulated release of radioactivity from Lhe rector coolant to i ts release to the environment and Lransport to the SITE OUNDARY, whi ch 1s relatable to at least 30 mi nutes decay time. The choi e of 15 minutes for the half-l ife cutoff was made because of the nu ear characteristics of the typical reactor coolant radioactivity T

radionuclides in lhe typical reactor coolant have half-lives of less an 4 minutes or half-l ives of greater than 14 minutes. which allows a

~HtARON HARRIS UN!l l B /4 4-:>

Amendment No

ADD: A Note prohibits application of LCO 3.0.4.b to an inoperable overpressure protection system. There is an increased risk associated with entering MODE 4 from MODE 5 with the overpressure protection system inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, cannot be applied to this circumstance.

REACTOR COOLANT SYSTEM BASES PRESSW[/TEMPERATURE LIMITS CContinued) heatup and the time (or coolant temperature) along the heatup raf!IP.

Furthennore. since the thermal stresses at the outside are tensile and increase with increasing heatup rate. a lower bound curve cannot be defined.

Rather. each heatup rat~ of interest must be analyzed on an individual basis.

Following the generation of pressure-teq:>erature curves for both the steady-state and finite heatup rate situations, the final limit curves are produced as follows. A c~site curve is constructed based on a point-by-point coq>arison of the steady-state and finite heatup rate data. At any given teq>erature. the allowable pressure is taken to be the lesser of the three values taken from the curves under consideration.

The use of the c~site curve is necessary to set conservative heatup limita-tions because it is possible for conditions to exist such that over the course of the heatup raq, the controlling condition switches from the inside to the outside and the pressure limit 111.1st at all times be based on analysis of the most critical criterion.

The c~site curves for the heatup rate data and the cooldown rate data in Figures 3.4-2 and 3.4-3 have not been adjusted for possible errors in the pressure and teq>erature sensin9 instruments. However. the heatu~ and cooldown curves in plant operating procedures have been adjusted for these instr1JDent errors. The instrument errors are controlled by the Technical Specification Equipment List Program. Plant Procedure PLP-106.

  • ISLH. pressure-teq>erature CP-T) curves may be used for inservice leak and hydrostatic tests with fuel in the reactor vessel. However. ISLH tests required by the ASHE code rrust be completed before the core is critical.

Altho~ the pressurizer operates in tef!IJ)erature ranges above those for which there is reason for concern of nonductile failure. operating limits are provided to assure compatibility of o~ration with the fatigue analysis performed in accordance with the ASHE Code requirements.

LPft TEMPERATURE OVERPRESSURE PROTECTION

,---'-+

~The OPERABILITY of two PORVs or an RCS vent o~ning of at least 2.9 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RC~ cold l~s.are less than or equal to 325°F. Eith~r PC;)RV has adequate relieving capability to protect the RCS from overpressurization when the transient is limited to either:

(1) the start of an idle RCP with the secondary water temperature of the steam generator less than 50°F above the RCS cold,eg t~ratures. or (2) the start of a charging/safety injection p!.Jq> and its injection into a water-solid RCS.

The maxinun allowed PORV setpoint for the Low Terl1)erature Overpressure Protection System (LTOPS) is derived by analysis which models the performance SHEARON HARRIS - UNIT 1 B 3/4 4-14 Amendment No. 68

SHEARON HARRIS - UNIT 1 B 3/4 5-1a Amendment No. 150 3/4.5 EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued) instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. If any accumulated gas is eliminated or brought within the acceptance criteria limits as part of the Surveillance performance, the Surveillance is considered met and the system is OPERABLE. Past operability is then evaluated under the Corrective Action program. If it is suspected that a gas intrusion event is occurring, then this is evaluated under the Operability Determination Process.

ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

With the RCS temperature below 350°F, one OPERABLE ECCS subsystem is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

The limitation for a maximum of one charging/safety injection pump to be OPERABLE and the Surveillance Requirement to verify one charging/safety injection pump OPERABLE below 325°F provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORV.

ADD:

A Note prohibits the application of LCO 3.0.4.b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

SHEARON HARRIS - UNIT 1 B 3/4 7-1a Amendment No. 154 3/4.7 PLANT SYSTEMS BASES 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM The OPERABILITY of the Auxiliary Feedwater System ensures that the Reactor Coolant System can be cooled down to less than 350°F from normal operating conditions so that the Residual Heat Removal System may be placed into operation. The AFW System provides decay heat removal immediately following a station blackout event, and is required to mitigate the Loss of Normal Feedwater and Feedwater Line break accidents analyzed in FSAR Chapter 15. The minimum pump performance requirements are based upon a maximum allowable degradation of the pump performance curves. Pump operation at this level has been demonstrated by calculation to deliver sufficient AFW flow to satisfy the accident analysis acceptance criteria.

With regard to the AFW valve position verification of Surveillance Requirement 4.7.1.2.1 Sub-paragraph b.1, this requirement does not include in its scope the AFW flow control valves inline from the AFW motor-driven pump discharge header to each steam generator when they are equipped with an auto-open feature. The auto-open logic feature is designed to automatically open these valves upon receipt of an Engineered Safety Features System AFW start signal. As a consequence, valves with an auto-open feature do not have a "correct position" which must be verified. The valves may be in any position, in any MODE of operation thereby allowing full use of the AFW System for activities such as to adjust steam generator water levels prior to and during plant start-up, as an alternate feedwater system during hot standby, for cooldown operations, and to establish and maintain wet layup conditions in the steam generators.

ADD:

A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

3/4.8 ELECTRICAL POWER SYSTEMS BASES SHEARON HARRIS - UNIT 1 B 3/4 8-2 Amendment No. 154 Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977 as modified in accordance with the guidance of IE Notice 85-32, April 22, 1985; and 1.137, "Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979. Proper shedding and sequencing of loads are required functions for Emergency Diesel Generator OPERABILITY. Pressure testing of the diesel generator fuel oil piping at 110% of the system design pressure will only be required on the isolable portions of (1) fuel oil transfer pump discharge piping to the day tank, (2) fuel oil supply from the day tank to the diesel vendor-supplied piping, and (3) fuel oil return piping from the diesel vendor-supplied piping to the day tank regulator valve. The exemptions allowed by ASME Code Section XI will be invoked for the atmospheric day tanks and non-isolable piping. The surveillance frequencies are controlled in the Surveillance Frequency Control Program.

The inclusion of the loss of generator potential transformer circuit lockout trip is a design feature based upon coincident logic and is an anticipatory trip prior to diesel generator overspeed. In TS 4.8.1.1.2.f.13, the phrase all diesel generator trips refers to automatic protective trips.

The Surveillance Requirements for demonstrating the OPERABILITY of the station batteries are based on the recommendations of Regulatory Guide 1.129, "Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1980, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations." The performance test supporting the Surveillance Requirement incorporates the guidance of IEEE Std 450-2010. The surveillance frequencies are controlled in the Surveillance Frequency Control Program.

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage on float charge, connection resistance values, and the performance of battery service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates, and compares the battery capacity at that time with the rated capacity.

Table 4.8-2 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage, and specific gravity. The limits for the designated pilot cells float voltage and specific gravity, greater than 2.13 volts and 0.015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adequate capacity. The normal limits for each connected cell for float voltage and specific gravity, greater than 2.13 volts and not more than 0.020 below the manufacturer's full charge specific gravity with an average specific gravity of all the connected cells not more than 0.010 below the manufacturer's full charge specific gravity, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days. During this 7-day period: (1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than 0.020 below the manufacturer's recommended full charge specific gravity, ensures that the decrease in rating will be less than the safety margin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than 0.040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability to perform its design function.

ADD: <INSERT C>

< INSERT C >

A Note prohibits the application of LCO 3.0.4.b to an inoperable diesel generator. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable diesel generator and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 5 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES FOR ONS (MARK-UP)

OCONEE NUCLEAR STATION, UNIT NOS. 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, AND DPR-55 19 PAGES (INCLUDING COVER)

LCO Applicability B 3.0 BASES OCONEE UNITS 1, 2, & 3 B 3.0-4 Rev. 004 LCO 3.0.3 The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 (continued) when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering the next lower MODE applies. If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering MODE 4 is the next 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, because the total time for entering MODE 4 is not reduced from the allowable limit of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.11, "Spent Fuel Pool Water Level." LCO 3.7.11 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.11 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.11 of "Suspend movement of irradiated fuel assemblies in spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It precludes placing the unit in a MODE or other specified condition stated in that Applicability (e.g., Applicability desired to be entered) when the following exist:

a.

Unit conditions are such that the requirements of the LCO would not be met in the Applicability desired to be entered; and

b.

Continued noncompliance with the LCO requirements, if the Applicability were entered, would result in the unit being required to Replace with

<INSERT A>

LCO Applicability B 3.0 BASES OCONEE UNITS 1, 2, & 3 B 3.0-5 Rev. 004 LCO 3.0.4 exit the Applicability desired to be entered to comply with the Required (continued)

Actions. Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made and the Required Actions followed after entry into the Applicability. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

For example, the provisions of LCO 3.0.4 may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION (Required Action and associated Completion Time not met) allows the OPERABLE train to be placed in operation, use of LCO 3.0.4 is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. The exceptions allows entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time. Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

LCO 3.0.4 is only applicable when entering MODE 4 from MODE 5, MODE 3 from MODE 4, MODE 2 from MODE 3, or MODE 1 from MODE 2.

Furthermore, LCO 3.0.4 is applicable when entering any other specified condition in the Applicability associated with operating in MODES 1, 2, 3, or

4. The requirements of LCO 3.0.4 do not apply in MODES 5 and 6, or in other specified conditions of the Applicability (unless in MODES 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

LCO Applicability B 3.0 BASES OCONEE UNITS 1, 2, & 3 B 3.0-6 Rev. 004 LCO 3.0.4 Surveillances do not have to be performed on the associated inoperable (continued) equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, changing MODES or other specified conditions while in an ACTIONS Condition, in compliance with LCO 3.0.4 or where an exception to LCO 3.0.4 is stated, is not a violation of SR 3.0.1 or SR 3.0.4 for those Surveillances that do not have to be performed due to the associated inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing

< INSERT A >

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4 (b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Regulatory Guide 1.160 endorses the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions.

The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment.

However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

SR Applicability B 3.0 BASES (continued)

OCONEE UNITS 1, 2, & 3 B 3.0-18 Rev. 004 SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY SR 3.0.4 requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

However, in certain circumstances, failure to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO Applicability would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached.

Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

Replace with

<INSERT B>

.....____]- - - - - -

I

SR Applicability B 3.0 BASES OCONEE UNITS 1, 2, & 3 B 3.0-19 Rev. 004 SR 3.0.4 SR 3.0.4 is only applicable when entering MODE 4 from MODE 5, MODE 3 (continued) from MODE 4, MODE 2 from MODE 3, or MODE 1 from MODE 2.

Furthermore, SR 3.0.4 is applicable when entering any other specified condition in the Applicability associated with operation in MODES 1, 2, 3, or 4. The requirements of SR 3.0.4 do not apply in MODES 5 and 6, or in other specified conditions of the Applicability (unless in MODES 1, 2, 3, or

4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

< INSERT B >

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCOs Applicability, would have its Frequency specified such that it is not due until the specific conditions needed are met.

Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific format of SRs annotation is found in Section 1.4, Frequency.



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A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

allowance

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

OCONEE UNITS 1, 2, & 3 B 3.4.15-3 BASES REVISION 001 LCO (continued) possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Ref. 3).

The LCO requirements are satisfied when instruments of diverse measurement means are available. Thus, the containment normal sump level indication, in combination with a particulate or gaseous radioactivity monitor, provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is d 200qF and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation is much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS The Actions are modified by a Note indicating that the provisions of LCO 3.0.4 do not apply. As a result, a MODE change is allowed when the normal sump level indication and required radioactivity monitor are inoperable. This allowance is provided because other instrumentation is available to monitor RCS LEAKAGE.

A.1 and A.2 With containment normal sump level indication inoperable, no other form of sampling can provide the equivalent information.

However, the containment atmosphere activity monitor will provide indications of changes in leakage. Together with the containment atmosphere radioactivity monitor, the periodic surveillance for RCS inventory balance, SR 3.4.13.1, water inventory balance, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and

LPI B 3.5.3 BASES OCONEE UNITS 1, 2, & 3 B 3.5.3-5 Rev. 004 LCO The flow path for each train must maintain its designed independence (continued) outside containment to ensure that no single failure can disable both LPI trains. If train separation is not maintained outside containment then only one LPI train is considered OPERABLE.

APPLICABILITY In MODES 1, 2 and 3, the LPI train OPERABILITY requirements for the Design Basis Accident, a large break LOCA, are based on full power operation. The position requirements of the LPI discharge crossover valves inside containment for the CFT line break are based on full power operation. Although reduced power would not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES.

In MODE 4, one OPERABLE LPI train is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

In MODES 5 and 6, unit conditions are such that the probability of an event requiring LPI injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "DHR and Coolant Circulation-High Water Level," and LCO 3.9.5, "DHR and Coolant Circulation-Low Water Level."

ACTIONS A.1 With one LPI train inoperable in MODES 1, 2 or 3, the inoperable train must be returned to OPERABLE status within 7 days. The 7 day Completion Time is based on the findings of the deterministic and probabilistic analysis in Reference 6. Reference 6 concluded that extending the Completion Time to 7 days for an inoperable LPI train improves plant operational flexibility while simultaneously reducing overall plant risk. Specifically, the risk incurred by having the LPI train unavailable for a longer time at power will be substantially offset by the benefits associated with avoiding unnecessary plant transitions and by reducing risk during shutdown operations.

A Note prohibits the application of LCO 3.0.4.b to inoperable ECCS DHR loops when entering MODE 4 from MODE 5. There is an increased risk associated with entering MODE 4 from MODE 5 with DHR inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

EFW System B 3.7.5 BASES OCONEE UNITS 1, 2, & 3 B 3.7.5-3 Rev. 002 LCO OPERABLE in accordance with Specification 3.3.14, "Emergency (continued)

Feedwater (EFW) Pump Initiation Circuitry." Automatic EFW steam generator level control is required to be OPERABLE when automatic EFW initiation is required to be OPERABLE. EFW automatic initiation instrumentation is not required to be OPERABLE in MODES 3 and 4 in accordance with LCO 3.3.14. In MODES 3 and 4 the EFW System is OPERABLE provided manual initiation capability is OPERABLE. Automatic initiation is not required in MODES 3 and 4 since additional time is available in these MODES for the operator to manually initiate the system if required.

When in MODE 3 and 4 automatic EFW flow control is not required to be OPERABLE provided manual steam generator level control is OPERABLE.

The LCO is modified by a Note indicating that one motor driven EFW pump and EFW flow path, is required in MODE 4 when an SG is relied upon for heat removal. This is because of reduced heat removal requirements, the short duration of MODE 4 in which feedwater is required, and the insufficient steam supply available in MODE 4 to power the turbine driven EFW pump.

APPLICABILITY In MODES 1, 2, and 3, the EFW System is required to be OPERABLE and to function in the event that the main feedwater is lost. In MODE 4, with RCS temperature above 212qF, the EFW System may be used for heat removal via the steam generators. In MODE 4, the steam generators are used for heat removal unless the DHR System is in operation. In MODE 4 steam generators are relied upon for heat removal whenever an RCS loop is required to be OPERABLE or operating to satisfy LCO 3.4.6, "RCS Loops - Mode 4."

In MODES 5 and 6, the steam generators are not used for DHR and the EFW System is not required.

ACTIONS A.1 With one of the motor driven EFW pumps inoperable, action must be taken to restore the MDEFW pump to OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a.

The redundant OPERABLE turbine driven EFW pump(s);

b.

The availability of the redundant OPERABLE motor driven EFW pump; and ADD <INSERT D>

< INSERT D >

A Note prohibits the application of LCO 3.0.4.b to an inoperable EFW train when entering MODE 1.

There is an increased risk associated with entering MODE 1 with EFW inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

PSW System B 3.7.10 BASES (continued)

OCONEE UNITS 1, 2, & 3 B 3.7.10-7 Rev. 004 APPLICABILITY In MODES 1 and 2, the PSW system provides a diverse means to achieve and maintain safe shutdown by providing secondary side DHR, reactor coolant pump seal cooling, primary system inventory control, and RCS boration for reactivity management during certain plant scenarios that disable the 4160 V essential electrical power distribution system.

As a result of the systems contribution to overall plant risk in mitigating transients initiated during these operating conditions, PSW is required to be OPERABLE in MODES 1 and 2. In MODES 3 and 4, the PSW system can provide a diverse means for secondary side DHR (while the steam generators remain available), reactor coolant pump seal cooling, primary system inventory control, and RCS boration for reactivity management.

Because of the relatively short periods of operation in these MODES, the contribution to the reduction of overall plant risk in mitigating transients initiated during these operating conditions is not sufficient to warrant inclusion of OPERABILITY requirements for MODES 3 and 4 in the Technical Specifications.

In MODES 5 and 6, the steam generators are not available for secondary side DHR. As such, the PSW feed to the SGs is not required. Protected Service Water system backup power to some of the HPI components may be relied upon for shutdown risk defense-in-depth associated with primary system makeup. There are multiple means to achieve primary system makeup during these conditions. As a result, the contribution to the reduction of overall plant risk during these operating conditions is not sufficient to warrant inclusion of OPERABILITY requirements for MODES 5 and 6 in the Technical Specifications.

ACTIONS The exception for LCO 3.0.4 provided in the NOTE of the Actions, permits entry into MODES 1 or 2 with the PSW system not OPERABLE. This is acceptable because the PSW is not required to support normal operation of the facility or to mitigate a design basis event.

A.1 With the PSW system inoperable, action must be taken to restore the system to OPERABLE status within 14 days. The 14-day Completion Time (CT) is reasonable based on the Standby Shutdown Facility (SSF) Auxiliary Service Water (ASW) and reactor coolant makeup (RCMU) systems being OPERABLE and a low probability of scenarios occurring that would require the PSW system during the 14 day period.

B.1 With both the PSW and SSF systems inoperable, action must be taken to restore the PSW system to OPERABLE status within 7 days. The 7 day

AC Sources - Operating B 3.8.1 BASES OCONEE UNITS 1, 2, & 3 B 3.8.1-6 Rev. 005 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 excludes 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.

Replace with

<INSERT E>

.....__________r----

I

< INSERT E >

A Note prohibits the application of LCO 3.0.4.b to an inoperable KHU. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable KHU and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

U.S. Nuclear Regulatory Commission Serial RA-20-0011 ATTACHMENT 6 LIST OF REGULATORY COMMITMENTS OCONEE NUCLEAR STATION, UNIT NOS. 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, AND DPR-55 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63 2 PAGES (INCLUDING COVER)

U.S. Nuclear Regulatory Commission Serial RA-20-0011 List of Regulatory Commitments The following table identifies those actions committed to by Duke Energy Progress, LLC (Duke Energy), in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Art Zaremba, Manager - Nuclear Fleet Licensing, at (980) 373-2062.

Regulatory Commitment Due Date/Event Duke Energy will establish the ONS Technical Specification Bases for LCO 3.0.4 and SR 3.0.4 as adopted with the applicable license amendment.

Upon implementation of the license amendment.

Duke Energy will establish the HNP Technical Specification Bases for LCO 3.0.4 and SR 4.0.4 as adopted with the applicable license amendment.

Upon implementation of the license amendment.