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Duke Energy - Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO
	ML21160A008
Person / Time
Site:	Oconee, Mcguire, Catawba, Robinson, McGuire
Issue date:	06/09/2021
From:	Hamilton T; Duke Energy Corp
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-19-0043
	Download: ML21160A008 (85)
	v • d • e

,-/

DUKE ENERGY.

Tanya Hamilton Senior Vice President Nuclear Corporate 526 South Church Street, EC-07H Charlotte, NC 28202 704-382-4035 Tanya.Hamilton@duke-energy.com 10 CFR 50.90 Serial: RA-19-0043 June 9, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17 OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3 DOCKET NOS. 50-269, 50-270 AND 50-287 / RENEWED LICENSE NOS. DPR-38, DPR-4 7 AND DPR-55 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as "Duke Energy," is submitting a request for an amendment to the Technical Specifications (TS) for Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS), Units 1 and 2; Oconee Nuclear Station (ONS), Units 1, 2 and 3; and H. B. Robinson Steam Electric Plant (RNP), Unit 2.

Consistent with Technical Specifications Task Force Traveler 439 (TSTF-439) Revision 2, the proposed amendment deletes second Completion times from the affected Required Actions contained in TS, along with removing the example contained in TS Section 1.3 and adding a discussion about alternating between Conditions. TSTF-439 has been incorporated into NUREG-1431, Standard Technical Specifications for Westinghouse Plants and NUREG-1430, Standard Technical Specifications for Babcock & Wilcox Plants.

The Enclosure provides a description and assessment of the proposed changes. In addition, the Enclosure concludes that the proposed amendment does not involve a significant hazards consideration. Attachment 1 of the Enclosure provides the existing TS pages marked to show the proposed changes. Attachment 2 of the Enclosure provides a markup of the current TS

U.S. Nuclear Regulatory Commission RA-19-0043 Page 2 Bases pages associated with this change, for information only. The retyped TS pages will be provided to the NRC immediately prior to issuance of the approved amendments.

There are no regulatory commitments contained in this letter.

Duke Energy requests review and approval of this license amendment request within one year of acceptance. The amendments shall be implemented within 120 days following approval.

In accordance with 1 O CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina and South Carolina state officials.

If you should have any questions regarding this submittal, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062.

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

Executed on June 9, 2021.

Sincerely, Tanya Hamilton Senior Vice President - Nuclear Corporate NOE

Enclosure:

Description and Assessment of the Proposed Change Attachments: 1. Proposed Technical Specification Changes (Mark-up)

2. Proposed Technical Specification Bases Pages (For Information Only)

U.S. Nuclear Regulatory Commission RA-19-0043 Page 3 cc (with Attachments):

L. Dudes, USNRC Region II - Regional Administrator N. Jordan, USNRC - Chief, TS Branch G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Nadel, USNRC Senior Resident Inspector - ONS J. D. Austin, USNRC Senior Resident Inspector - CNS M. Fannon, USNRC Senior Resident Inspector - RNP A. Hon, NRR Project Manager-Fleet S. Jenkins, Chief, Bureau of Radiological Health (SC)

A. Wilson, Attorney General (SC)

W. L. Cox, Ill, Section Chief, North Carolina Department of Health and Human Services, RP Section (NC)

L. Garner, Manager, Radioactive and Infectious Waste Management (SC)

Chairman, North Carolina Utilities Commission

Enclosure:

Description and Assessment of the Proposed Change

Subject:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-439, "ELIMINATE SECOND COMPLETION TIMES LIMITING FROM DISCOVERY OF FAILURE TO MEET AN LCO"

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1 Description of Proposed Change 2.2 Description of Variances

3.

TECHNICAL EVALUATION

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Analysis 4.4 Conclusions

5.

ENVIRONMENTAL CONSIDERATION

6.

REFERENCES

U.S. Nuclear Regulatory Commission RA-19-0043 Page 2

1.

SUMMARY

DESCRIPTION Duke Energy requests an amendment to the Technical Specifications (TS) for Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS), Units 1 and 2; Oconee Nuclear Station (ONS), Units 1, 2 and 3; and H. 8. Robinson Steam Electric Plant (RNP), Unit 2.

Consistent with Technical Specifications Task Force Traveler 439 (TSTF-439), Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" (Reference 1), the proposed amendment deletes second Completion Times from the affected Required Actions contained in TS, along with removing the example contained in TS Section 1.3 and adding a discussion about alternating between Conditions.

2.

2.1 DETAILED DESCRIPTION Description of Proposed Change Reference 1 deletes second Completion Times from TS that were originally included for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the Limiting Condition for Operation (LCO). Reference 1 also modifies Improved Technical Specifications (TS) (NUREG-1430 and NUREG-1431) Completion Times Example 1.3-3 to eliminate the second Completion Times and to replace the discussion regarding second Completion Times with a new discussion.

TSTF-439, Revision 2, has been incorporated into NUREG-1430, Volume 1, Revision 4 (Reference 2) and NUREG-1431, Volume 1, Revision 4 (Reference 3), as identified in a letter from the NRC to the TSTF (Reference 4).

Consistent with TSTF-439, the proposed change: (1) modifies Completion Times Example 1.3-3 to eliminate the second Completion Times contained within and revises the discussion in the example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the bases of the Completion Times and is inappropriate, and (2) removes second Completion Times contained in the TS. Specifically, the following second Completion Times are proposed to be removed:

Catawba o

TS 3. 7.5 Required Actions A.1 and 8.1 o

TS 3.8.1 Required Actions A.3, 8.6 and D.6 o

TS 3.8.9 Required Actions A.1, 8.1, C.1 and D.1 McGuire o

TS 3.7.5 Required Actions A.1 and 8.1 o

TS 3.8.1 Required Actions A.3 and 8.6 o

TS 3.8.9 Required Actions A.1, 8.1 and C.1 Oconee o

TS 3.6.5 Required Actions A.1 and 8.1 o

TS 3. 7.5 Required Actions A.1 and 8.1 o

TS 3.8.1 Required Actions C.2.1 and D.3

U.S. Nuclear Regulatory Commission RA-19-0043 Page 3 Robinson o

TS 3.6.6 Required Actions A.1 and C.1 o

TS 3.7.4 Required Actions A.1 and B.1 o

TS 3.8.1 Required Actions A.3 and B.4 o

TS 3.8.9 Required Actions A.1, B.1 and C.1 2.2 Description of Variances Duke Energy is proposing the following variances from the TS changes described in TSTF-439.

These variations do not affect the applicability of TSTF-439 to the proposed license amendment.

Affected Duke Energy Comments TSTF-439 Station(s)

Variation Catawba TS 3.6.6, Containment Spray No change made The Completion Time System for the equivalent Catawba TS does not include a second Completion Time.

Catawba TS 3.8.1, AC Sources, TS 3.8.1, AC Sources, The fourth Completion Required Action A.3 and B.4 Required Action B.6 Time of CNS TS 3.8.1 second Completion Time and D.6 fourth Required Action B.6 is deleted.

Completion Time equivalent to the deleted second Completion Time of TSTF-439 TS 3.8.1 Required Action B.4 and is numbering difference only.

With the issuance of Catawba amendments 304 and 300 (ADAMS Accession No. ML19212A655), LCOs and associated Actions were added to TS 3.8.1 to account for qualified offsite circuits and emergency diesel generators on the opposite unit.

Required Action D.6 is equivalent to Required Action B.6, the only difference being that

U.S. Nuclear Regulatory Commission RA-19-0043 Page4 Affected TSTF-439 Station(s)

Catawba TS 3.8.9, Distribution Systems - Operating, Required Actions A.1, B.1 and C.1 second Completion Time deleted.

McGuire TS 3.6.6, Containment Spray System McGuire TS 3.8.1, AC Sources, Required Action A.3 and B.4 second Completion Time deleted.

Oconee TS 3.6.6, Containment Spray and Cooling Systems, Required Action A.1 and C.1 second Completion Time deleted.

Duke Energy Variation TS 3.8.9, Distribution Systems - Operating, Required Actions A.1, B.1, C.1 and 0.1 second Completion Time deleted No change made TS 3.8.1, AC Sources, Required Action B.6 fourth Completion Time deleted.

TS 3.6.5, Reactor Building Spray and Cooling Systems, Required Action A.1 and B.1 second Completion Time deleted.

Comments Required Action 0.6 is associated with an inoperable diesel generator on the opposite unit.

Catawba TS Condition C is applicable to one channel of DC electrical power distribution subsystems, while an additional Condition D is applicable to one train of DC electrical power distribution subsystems. The TSTF-439 applies to both conditions.

The Completion Time for the equivalent McGuire TS does not include a second Completion Time.

The fourth Completion Time of MNS TS 3.8.1 Required Action 8.6 is equivalent to the second Completion Time of TSTF-439 TS 3.8.1, Required Action B.4 and is a numbering difference only.

Numbering and Name difference only.

U.S. Nuclear Regulatory Commission RA-19-0043 Page 5 Affected TSTF-439 Station(s)

Oconee TS 3.8.1, AC Sources -

Operating, Required Actions A3 and B4 second Completion Time deleted.

Oconee TS 3.8.9, Distribution Systems - Operating, Required Actions A.1, B.1 and C.1 second Completion Time deleted.

Robinson TS 3.7.5, Auxiliary Feedwater System Catawba TS 3.8.1 AC Sources - Operating Duke Energy Comments Variation TS 3.8.1, AC Sources The Oconee AC Power

- Operating, Required System consists of the Actions C.2.1 and D.3 offsite power sources second Completion and the onsite standby Time deleted power sources, Keowee Hydro Units (KHU). The TSTF-439 applies to both Oconee TS Required Actions C.2.1 and D.3. Further discussion of this variance is provided below.

TS 3.8.8, Distribution Numbering difference Systems - Operating, and the Oconee TS no change made.

does not include a second Completion Time TS 3.7.4, Auxiliary Numbering difference Feedwater (AFW) only.

System

TS 3.8.1, Required Action D.6, One LCO 3.8.1.d DG inoperable In accordance with Branch Technical Position 8-8, operation may continue in Condition D for a period that should not exceed 14 days, provided a supplemental AC power source is available.

In Condition D, the remaining OPERABLE DGs, unavailable ESPS, and offsite power circuits are adequate to supply electrical power to the Class 1 E Distribution System. The 14 day Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

If the ESPS is or becomes unavailable with an inoperable LCO 3.8.1.d DG, then action is required to restore the ESPS to available status or to restore the DG to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of unavailable ESPS. However, if the ESPS unavailability occurs at or sometime after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of continuous LCO 3.8.1.d DG inoperability, then the remaining time to restore the ESPS to available status or to restore the DG to OPERABLE status is limited to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

U.S. Nuclear Regulatory Commission RA-19-0043 Page 6 The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times allow for an exception to the normal "time zero" for beginning the allowed outage time "clock." The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time only begins on discovery that both:

An inoperable DG exists; and ESPS is unavailable.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time only begins on discovery that

An inoperable DG exists for 2: 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ; and ESPS is unavailable.

Therefore, when one LCO 3.8.1.d DG is inoperable due to either preplanned maintenance (preventive or corrective) or unplanned corrective maintenance work, the Completion Time can be extended from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days if ESPS is verified available for backup operation.

The fourth Completion Time for Required Action D.6 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet LCO 3.8.1.c or LCO 3.8.1.d. If Condition D is entered while, for instance, a LCO 3.8.1.c offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This could lead to a total of 17 days, since initial failure to meet LCO 3.8.1.c or LCO 3.8.1.d, to restore the DG. At this time, a LCO 3.8.1.c offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to complete restoration of LCO 3.8.1.c and LCO 3.8.1.d. The 17 day Completion Time provides a limit on time allowed in a specified condition after discovery of failure to meet LCO 3.8.1.c or LCO 3.8.1.d. This limit is considered reasonable for situations in which Conditions C and D are entered concurrently. The "AND" connector between the 14 day and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive Completion Time must be met.

The Reactor Oversight Process monitors the availability of mitigating systems, including the AC sources. Such frequent, repeated failures or extended unavailability of the AC electrical distribution system would be reported to the NRC and this represents a strong disincentive to such operation. Additionally, the Maintenance Rule requires a comprehensive program which provides much greater assurance of safe plant operation than the second Completion Times in the TSs. Therefore, the second Completion Time for Required Action D.6 is not required.

Oconee TS 3.8.1 AC Sources - Operating The AC Power System consists of the offsite power sources (preferred power) and the onsite standby power sources, Keowee Hydro Units (KHU).

The preferred power source is provided from offsite power to the red or yellow bus in the 230 kV switchyard to the units startup transformer and the E breakers. The 230 kV switchyard is electrically connected to the 525 kV switchyard via the auto bank transformer. Emergency power is provided using two emergency power paths, an overhead path and an underground path. The underground emergency power path is from one KHU through the underground

U.S. Nuclear Regulatory Commission RA-19-0043 Page 7 feeder circuit, transformer CT-4, the CT-4 incoming breakers (SK breakers), standby bus and the standby breakers (S breakers). The standby buses may also receive offsite power from the 100 kV transmission system through transformer CT-5 and the CT-5 incoming breakers (SL breakers). The overhead emergency power path is from the other KHU through the startup transformer and the startup incoming breakers (E breakers).

TS 3.8.1 Required Action C.2.1, KHU or its required overhead emergency power path inoperable due to reasons other than Condition A With the KHU or its required overhead emergency power path inoperable due to reasons other than an inoperable startup transformer (Condition A), sufficient AC power sources remain available to ensure safe shutdown of the unit in the event of a transient or accident.

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

Similar to the "Background" section of TSTF-439, it would be theoretically possible in the scenario described above for ONS TS 3.8.1 Condition C to operate indefinitely without ever meeting the LCO. However, the Reactor Oversight Process monitors the availability of mitigating systems, including the AC sources. Such frequent, repeated failures or extended unavailability of the AC sources would be reported to the NRG and this represents a strong disincentive to such operation. Additionally, the Maintenance Rule requires a comprehensive program which provides much greater assurance of safe plant operation than the second Completion Times in the TSs. Therefore, the justification provided by TSTF-439 for the elimination of second Completion Times is directly applicable to ONS TS 3.8.1 Required Action C.2.1.

TS 3.8.1 Required Action D.3, KHU or its required underground power path inoperable With the KHU or its required underground emergency power path inoperable, sufficient AC power sources remain available to ensure safe shutdown of the unit in the event of a transient or accident.

The second Completion Time for Required Action D.3 establishes a limit on the maximum time allowed for a KHU to be inoperable during any single contiguous occurrence of having a KHU inoperable. If Condition D is entered as a result of switching an inoperable KHU from the

U.S. Nuclear Regulatory Commission RA-19-0043 Page 8 overhead to the underground emergency power path, it may have been inoperable for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This could lead to a total of 144 hours0.00167 days 0.04 hours 2.380952e-4 weeks 5.4792e-5 months since the initial failure of the KHU. The second Completion Time allows for an exception to the normal "time zero" for beginning the allowed time "clock." This will result in establishing the "time zero" at the time the KHU become inoperable, instead of at the time Condition D was entered.

Similar to the "Background" section of TSTF-439, it would be theoretically possible in the scenario described above for ONS TS 3.8.1 Condition C to operate indefinitely without ever meeting the LCO. However, the Reactor Oversight Process monitors the availability of mitigating systems, including the AC sources. Such frequent, repeated failures or extended unavailability of the AC sources would be reported to the NRC and this represents a strong disincentive to such operation. Additionally, the Maintenance Rule requires a comprehensive program which provides much greater assurance of safe plant operation than the second Completion Times in the TSs. Therefore, the justification provided by TSTF-439 for the elimination of second Completion Times is directly applicable to ONS TS 3.8.1 Required Action D.3.

3.

TECHNICAL EVALUATION As discussed in TSTF-439, Revision 2, the adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, there was no regulatory requirement or program which could prevent this misuse of the TS. However, that is no longer the case. With the promulgation of the Maintenance Rule, implementation of the Reactor Oversight Process, and the inclusion of administrative controls as discussed herein, there would exist strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.

Maintenance Rule 10 CFR 50.65(a)(1), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (i.e., the Maintenance Rule), requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor the licensee's Corrective Action Program (CAP) and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 (a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the TS and unacceptable unavailability of these SSCs.

The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65 (a)(3).

Under the TS, the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO. However, 10 CFR 50.65(a)(4) is a much better mechanism to apply this

U.S. Nuclear Regulatory Commission RA-19-0043 Page 9 influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." (Reference 5)

Regulatory Guide 1.160 endorses the Revision 4A of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (Reference 6). 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, reduce the duration of the condition, minimize the magnitude of risk increases through the establishment of backup success paths or compensatory measures, and determination that the proposed maintenance is acceptable.

This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the TS.

Reactor Oversight Process Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP) (Reference 7). The NEI document is endorsed by Regulatory Issue Summary (RIS) 2001-11, "Voluntary Submission of Performance Indicator Data" (Reference 8). NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone.

NEI 99-02 specifically addresses Emergency AC Sources, which encompasses the AC Sources and Distribution System LCOs, and the Auxiliary Feedwater System. Extended unavailability of these systems due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the ROP.

Administrative Controls In addition to these programs, a requirement is added to Section 1.3 of the TS to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This TS requirement, when considered with the regulatory processes discussed above, provide an equivalent or superior level of plant safety without the unnecessary complication of the TS by second Completion Times on some Specifications.

U.S. Nuclear Regulatory Commission RA-19-0043 Page 10 As part of the implementation process for this TS change, Duke Energy plans to add a statement similar to the following to the appropriate fleet procedure for CNS, MNS, ONS and RNP.

It is possible to alternate between TS Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so is inconsistent with the basis of the Completion Times. Therefore, the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO shall be limited.

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The following NRC requirements are applicable to the proposed change.

Title 1 O Code of Federal Regulations 50.35(c)(2)

The regulations of Title 10 of the Code of Federal Regulations (1 O CFR), "Technical Specifications," establish the requirements related to the content of the TS. Section 50.36(c)(2) states:

When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

Title 1 O Code of Federal Regulations 50.65 The regulations of 1 O CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," establish a performance-based rule to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

The proposed changes continue to meet the requirements of these regulations.

4.2 Precedent The proposed change is consistent with NRC-approved license amendments issued to Prairie Island on June 6, 2019 (Reference 9), Duke Energy on September 23, 2019 (Reference 10),

and Exelon on October 8, 2019 (Reference 11 ).

4.3 No Significant Hazards Consideration Analysis Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as "Duke Energy," requests adoption of Technical Specification Task Force (TSTF)

Traveler TSTF-439, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO," which is an approved change to the Standard Technical Specifications (STS), into the Catawba Nuclear Station (CNS), Units 1 and 2, McGuire Nuclear Station (MNS), Units 1 and 2, Oconee Nuclear Station (ONS), Units 1, 2 and 3, and the H. B.

U.S. Nuclear Regulatory Commission RA-19-0043 Page 11 Robinson Steam Electric Plant (RNP), Unit 2, Technical Specifications (TS). The proposed change deletes second Completion Times from the affected Required Actions contained in TS, along with removing the example contained in TS Section 1.3 and adding a discussion about alternating between Conditions. These changes are consistent with NRG-approved Traveler TSTF-439, Revision 2.

Duke Energy has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change eliminates second Completion Times from the Technical Specifications. Completion Times are not an initiator to any accident previously evaluated. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the probability and consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of systems, structures, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite nor significantly increase individual or cumulative occupational/public radiation exposures.

The proposed change is consistent with the safety analysis assumptions and resultant consequences.

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

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change will not alter the design function, nor create new failure mechanisms, malfunctions, or accident initiators for the equipment related to the TS being altered.

Thus, based on the above, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

U.S. Nuclear Regulatory Commission RA-19-0043 Page 12

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings, or limited conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change.

The proposed change will not result in plant operation in a configuration outside of the design basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.

ENVIRONMENTAL CONSIDERATION The proposed change would alter a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 O CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.

REFERENCES

1.

Letter from the TSTF to the NRC, "TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," dated June 20, 2005 (ADAMS Accession No. ML051860296).

2.

NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants, Volume 1, Rev. 4, dated April 2012.

3.

NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Rev.

4, dated April 2012.

U.S. Nuclear Regulatory Commission RA-19-0043 Page 13

4.

Letter from Thomas H. Boyce, Technical Specifications Branch Chief (U.S. Nuclear Regulatory Commission) to the Technical Specifications Task Force, "Status of TSTF 439, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," dated January 11, 2006 (ADAMS Accession No. ML060120272).

5.

U.S. Nuclear Regulatory Commission Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated May 2012 (ADAMS Accession No. ML113610098).

6.

Nuclear Energy Institute (NEI), NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 4A, April 26, 2011 (ADAMS Accession No. ML11116A198).

7.

NEI Guideline, NEI 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 7, dated August 31, 2013 (ADAMS Accession No. ML13261A116).

8.

NRC Regulatory Issue Summary (RIS), RIS-2001-11, "Voluntary Submission of Performance Indicator Data," dated May 11, 2001 (ADAMS Accession No. ML011240144).

9.

Letter from the NRC to S. Sharp, "Prairie Island Nuclear Generation Plant, Units 1 and 2

- Issuance of Amendments Re: TSTF-439 'Eliminated Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO' (EPID L-2018-LLA-0178),"

dated June 6, 2019. (ADAMS Accession No. ML19128A133).

10.

Letter from the NRC to W.R. Gideon, "Brunswick Steam Electric Plant, Units 1 and 2 -

Issuance of Amendment Nos. 293 and 321 to Adopt TSTF-439, revision 2, 'Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO' (EPID L-2018-LLA-0220)," dated September 23, 2019 (ADAMS Accession No. ML19233A073).

11.

Letter from the NRC to B.C. Hanson, "Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments to Eliminate Second Completion Times from Technical Specifications (EPID L-2018-LLA-0297)," dated October 8, 2019 (ADAMS Accession No. ML19266A527).

U.S. Nuclear Regulatory Commission RA-19-0043, Attachment PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Completion Times 1.3 1.3 Completion Times (continued)

DESCRIPTION (continued)

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " Example 1.3 3 illustrates one use of this type of Completion Time. The 1 O day Completion Time speoified for Conditions /\\. and B in Example 1.3 3 may not be extended.

(continued)

Catawba Units 1 and 2 1.3-3 Amendment Nos. 298/294

1.3 Completion Times EXAMPLES

( continued)

EXAMPLE 1.3-3 ACTIONS CONDITION A.

One Function X train inoperable.

8.

One Function Y train inoperable.

C.

One Function X train inoperable.

AND One Function Y train inoperable.

Catawba Units 1 and 2 REQUIRED ACTION A.1 Restore Function X train to OPERABLE status.

8.1 Restore Function Y train to OPERABLE status.

C. 1 Restore Function X train to OPERABLE status.

OR C.2 Restore Function Y train to OPERABLE status.

Completion Times 1.3 COMPLETION TIME 7 days ANQ Hl elays fFem elisseYeF)1 ef fail~Fe te meet tl=le bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANQ Hl elays fFem elissei.1ei:y ef rail~Fe te ff\\eet tl=le bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued) 1.3-7 Amendment Nos. 298/294

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B are modified by a logical connector with a separate 10 day Completion Time measured from the time it 1.vas discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions /1., B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from disco1*1ery of failure to meet the LCO" is designed to prei.1ent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

INSERT:

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

Catawba Units 1 and 2 1.3-8 Amendment Nos. 298/294

3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

AFW System 3.7.5

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

Only one AFW train, which includes a motor driven pump, is 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

NOTE---

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

CONDITION REQUIRED ACTION COMPLETION TIME A. One steam supply to A.1 Restore affected 7 days turbine driven AFW equipment to OPERABLE pump inoperable.

status.

AND OR

~Q days frnm

NOTE discovery of Only applicable if Mode failure to 2 has not been entered meettl:le LGO following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

B.

One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable in MODE 1, 2 OPERABLE status.

or 3 for reasons other AND than Condition A.

~ Q days fi:om dlscovery of failure to meet tl:le LGO (continued)

Catawba Units 1 and 2 3.7.5-1 Amendment Nos. 295129-ACTIONS AC Sources - Operating 3.8.1

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One LCO 3.8.1.a offsite A.1 Perform SR 3.8.1.1 for required OPERABLE offsite circuit(s).

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable.

Catawba Units 1 and 2 AND A.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

A.3 Restore offsite circuit to OPERABLE status.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 17 days from disoovery of failure to meet LGO 3.8.1.a or LGO 3.8.1.b 3.8.1-2 Amendment Nos. 3041300

ACTIONS CONDITION B.

(continued)

B.5 AND B.6 Catawba Units 1 and 2 REQUIRED ACTION Evaluate availability of Emergency Supplemental Power Source (ESPS).

AC Sources - Operating 3.8.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter Restore DG to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from status.

3.8.1-4 discovery of unavailable ESPS 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition B entry ~

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concurrent with unavailability of ESPS AND 14 days 17 days from disoovery of failure to meet LGO 3.8.1.a or LGO 3.8.1.b Amendment Nos. 304/300

ACTIONS (continued)

CONDITION D.

(continued)

Catawba Units 1 and 2 REQUIRED ACTION D.4.1 Determine OPERABLE DG(s) is not inoperable due to common cause failures.

OR D.4.2 Perform SR 3.8.1.2 for OPERABLE DG(s).

D.5 Evaluate availability of ESPS.

AND AC Sources - Operating 3.8.1 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter D.6 Restore LCO 3.8.1.d DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from OPERABLE status.

discovery of unavailable ESPS 3.8.1-7 AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition D entry ~

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concurrent with unavailability of ESPS AND 14 days ANB 17 days from disoovery of failure to meet LGO :3.8.1.o or LGO :3.8.1.d Amendment Nos. :304/:300

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating Distribution Systems - Operating 3.8.9 LCO 3.8.9 Train A and Train B AC, four channels of DC, DC Train A and Train B and four AC vital buses electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem(s) subsystem(s) to ANO inoperable.

OPERABLE status.

1 e ROl:11:s fFOA=l disGovei:y of faih:ir:e to meet bCO B.

One AC vital bus B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable.

subsystem to OPERABLE status.

ANO

+6-ool:H'-S--fr:Gm disG01Jei:}1 of faih:ir:e to meetbCO (continued)

Catawba Units 1 and 2 3.8.9-1 Amendment Nos. 173/1 e5

ACTIONS (continued)

CONDITION C.

One channel of DC C. 1 electrical power distribution subsystems inoperable.

D.

One train of DC D.1 electrical power distribution subsystems inoperable.

E.

Required Action and E.1 associated Completion Time not met.

AND E.2 F.

Two trains with F.1 inoperable distribution subsystems that result in a loss of safety function.

Catawba Units 1 and 2 Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore channel of DC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power distribution subsystems to OPERABLE AND status.

16 l:lg1:1~s f~gm dissg1.ie~1 gf fai11:1~e tg meet bGO Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution subsystem to OPERABLE AND status.

161:lgms frGm dissg1,1ei:y gf fail1:1~e tg meet bGO Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Enter LCO 3.0.3.

Immediately 3.8.9-2 Amendment Nos. 173/165

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " Example 1.3 3 illustrates one use of this typo of Completion Time. The 10 day Completion Time speoifiod for Conditions /1.. and B in Example 1.3 3 may not be extended.

McGuire Units 1 and 2 1.3-3 (continued)

Amendment Nos. 307/286

1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS CONDITION A.

One Function X train inoperable.

B.

One Function Y train inoperable.

C.

One Function X train inoperable.

AND One Function Y train inoperable.

McGuire Units 1 and 2 REQUIRED ACTION A.1 Restore Function X train to OPERABLE status.

B.1 Restore Function Y train to OPERABLE status.

C.1 Restore Function X train to OPERABLE status.

OR C.2 Restore Function Y train to OPERABLE status.

Completion Times 1.3 COMPLETION TIME 7 days ANQ rn Elays fFem Eliseai.iept af faill:lF0 ta meet tl=1e bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANQ

~ Q Elays fFam Elisea.. 1ei:y af faill:lFe ta meet U:ie bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued) 1.3-7 Amendment Nos. 3Q7/286

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

Tho Completion Times of Conditions /\\ and B are modified by a logisal sonnostor with a separate 10 day Completion Time measured from tho time it was disso11orod tho LCO was not mot. In this example, without tho separate Completion Time, it would be possible to alternate between Conditions /\\, B, and C in sush a manner that operation sould sontinuo indefinitely '..'ithout e¥er restoring systems to moot the LCO. The separate Completion Time modified by tho phrase "from disso¥ery of failure to meet the LCO" is designed to pro*1ent indefinite sontinued operation *..<hilo not mooting the LCO. This Completion Time allows for an exseption to the normal "time zero" for beginning tho Completion Time "slosk". In this instanse, the Completion Time "time zero" is spesified as sommoncing at tho time tho LCO \\\\1as initially not mot, instead of at tho time the assosiatod Condition was entered.

INSERT:

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

McGuire Units 1 and 2 1.3-8 Amendment Nos. 307/286

3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

AFW System 3.7.5 NOTE--------------

Only one AFW train, which includes a motor driven pump, is 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

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

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

CONDITION REQUIRED ACTION COMPLETION TIME A.

One steam supply to A.1 Restore affected equipment 7 days turbine driven AFW to OPERABLE status.

pump inoperable.

A-NB OR Hl lays fFaFR NOTE Elisoa'l'eFY af failurn ta Only applicable if MODE meetU:ie bGG 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

B.

One AFW train 8.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable in MODE 1, 2 OPERABLE status.

or 3 for reasons other A-NB than Condition A.

Hl lays fFaFR Elisoa11ef)' af failuFe ta FReettl=ie bGG (continued)

McGuire Units 1 and 2 3.7.5-1 Amendment Nos. a16/296

ACTIONS AC Sources - Operating 3.8.1

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One LCO 3.8.1.a offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable.

McGuire Units 1 and 2 required OPERABLE offsite circuit(s).

AND AND A.2 AND Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

A.3 Restore offsite circuit to OPERABLE status.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANG 17 days from disoovery of failure to meet LGO a.8.1.a or LGO 3.8.1.b 3.8.1-2 Amendment No. 314/293

ACTIONS (continued)

CONDITION B.

( continued)

McGuire Units 1 and 2 REQUIRED ACTION AC Sources - Operating 3.8.1 COMPLETION TIME 8.5 Evaluate availability of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Emergency Supplemental Power Source (ESPS).

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 8.6 Restore DG to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from status.

discovery of unavailable ESPS 3.8.1-4 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition B entry ~

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concurrent with unavailability of ESPS 14 days 17 days from disoo... ery of failure to meet LGO 3.8.1.a or LGO 3.8.1.b Amendment No. 3161206

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating Distribution Systems - Operating 3.8.9 LCO 3.8.9 Train A and Train B AC, four channels of DC, and four AC vital buses electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more AC A. 1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystem(s) subsystem(s) to ANQ.

inoperable.

OPERABLE status.

16 l=!gi,us frgm diSGQ1Jer-y gf faih:1re tg meet LGQ B.

One AC vital bus 8.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months inoperable.

subsystem to OPERABLE status.

ANQ.

16 l=!gblrs frnm disGQ!Jery-Gf-.failblre tg meet LGQ (continued)

McGuire Units 1 and 2 3.8.9-1 Amendment No. 184/166

ACTIONS (continued)

CONDITION C.

One channel of DC C.1 electrical power distribution subsystem inoperable.

D.

Required Action and D.1 associated Completion Time not met.

AND D.2 E.

Two trains with E.1 inoperable distribution subsystems that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore DC channel of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power distribution subsystem to OPERABLE ANO status.

16 i:IQbl~S frnm diSGQ\\!ei:y Qf failbl~e tQ meet bGG Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Enter LCO 3.0.3.

Immediately SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program McGuire Units 1 and 2 3.8.9-2 Amendment No. 261/241

Completion Times 1.3 1.3 Completion Times DESCRIPTION

( continued)

EXAMPLES The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " Example 1.3 3 illustrates one use of this type of Completion Time. The 1 O day Completion Time specified for Conditions A and-S-iA-sxample-1.3-3-may not be exteAded-a-The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met.

B.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months ) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

OCONEE UNITS 1, 2, & 3 1.3-3 Amendment Nos. 407, 409, & 408 I

1.3 Completion Times EXAMPLES

( continued)

EXAMPLE 1.3-3 ACTIONS CONDITION A.

One Function X train inoperable.

B.

One Function Y train inoperable.

C. One Function X train inoperable.

AND One Function Y train inoperable.

OCONEE UNITS 1, 2, & 3 REQUIRED ACTION A.1 Restore Function X train to OPERABLE status.

8.1 Restore Function Y train to OPERABLE status.

C.1 Restore Function X train to OPERABLE status.

OR C.2 Restore Function Y train to OPERABLE status.

Completion Times 1.3 COMPLETION TIME 7 days ANO 10 days fmm gj.sc;:g11ei:y gf raih,IR3 tg meettl'.le bGQ 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANO 10 days fmm gj.sc;:gvei:y gf railYf~

megttl:le bGQ 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 1.3-6 Amendment Nos. ~

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3 3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condit-iGn-G-aAd-traGkeci-fmm-the-time-the second train was declaf9d inoperable (i.e., the time-the situation described in Condition C was discovered).

If Required Action C.2 is completed 11.1ithin the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired.operation may continue in accordance 11+1ith Condition A. The remamiAg Completion Time in Condition A is measureci from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it woulci be possible to alternate between Conditions A, B, and C in such a manner that operation could continue inciefinitely without ever restoring systems to meet the LCO. The separate Completion-Time modifieci by the phrase "from diseo-ver-y-Gf failure to meet the LCO" is designed--tG-pFQlJ8R.t-iAciefiA~ntinued operation while not meeting the LCO. This Completion Time allows..f.Gr an exception to th~~ro" for beginning the Completion-Tim&

"clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

INSERT:

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

OCONEE UNITS 1, 2, & 3 1.3-7 Amendment Nos. 300, 300, &-JOO

Reactor Building Spray and Cooling Systems 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Reactor Building Spray and Cooling Systems LCO 3.6.5 Two reactor building spray trains and three reactor building cooling trains shall be OPERABLE.

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

Only one train of reactor building spray and two trains of reactor building cooling are required to be OPERABLE during MODES 3 and 4.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS

-------------------*--------NOTE--------------------------------------------

LCO 3.0.4 is not applicable for Unit 2.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One reactor building A.1 Restore reactor 7 days spray train inoperable in building spray train to MODE 1 or 2.

OPERABLE status.

ANQ

~ 4 elays fFelfl elisee11ept ef faih:1Fe te !fleet tl=le bGG B.

One reactor building B.1 Restore reactor 7 days cooling train inoperable building cooling train to in MODE 1 or 2.

OPERABLE status.

ANQ

~ 4 elays fFelfl eliseeYePJ ef failurn te !fleet tl=le bGG (continued)

OCONEE UNITS 1, 2, & 3 3.6.5-1 Amendment Nos. aoo, a4o, & aoo

EFW System 3.7.5 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 A. 1 Restore MDEFW pump 7 days inoperable in MODE 1, to OPERABLE status.

2, or 3.

ANG

~ 0 elays fFeFR elisse1.iei:;1 ef failurn to FReet the bGG B.

Turbine driven EFW 8.1 Restore turbine driven 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months pump inoperable in EFW pump and EFW MODE 1, 2, or 3.

flow path to ANG OPERABLE status.

OR

~ 0 elays fFeFR elissei.iep; ef failurn te FReet the One EFW flow path bGG inoperable in MODE 1, 2, or 3.

(continued)

OCONEE UNITS 1, 2, & 3 3.7.5-1 Amendment Nos. 300, 300, & 300

ACTIONS (continued)

CONDITION C.

KHU or its required overhead emergency power path inoperable due to reasons other than Condition A.

OCONEE UNITS 1, 2, & 3 AC Sources - Operating 3.8.1 REQUIRED ACTION COMPLETION TIME C.1 Perform SR 3.8.1.3 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months if not performed in OPERABLE KHU.

previous 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND Once per 7 days thereafter AND C.2.1 Restore the KHU and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months its required overhead emergency power path AN9 to OPERABLE status.

+2 l:101:lFS fF0FA eliS601atePj ef inepernble KHU OR C.2.2.1 Energize both standby 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months buses from LCT via isolated power path.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsequent discovery of deenergized standby bus AND C.2.2.2 Suspend KHU 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months generation to grid except for testing.

AND (continued) 3.8.1-3 Amendment Nos. 383, 386, & 384

ACTIONS CONDITION D. (continued)

AND 0.3 E.

Required Action and E.1 associated Completion Time not met for Required Action D.2.

AND E.2 F.

Zone overlap protection F.1 circuitry inoperable when overhead electrical disconnects for KHU associated OR with the underground power path are closed.

F.2 G.

Both emergency power G.1 paths inoperable due to one inoperable E breaker and one inoperable S breaker on the same main feeder bus.

OCONEE UNITS 1, 2, & 3 REQUIRED ACTION Restore KHU and its required underground emergency power path to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

Restore zone overlap protection circuitry to OPERABLE status.

Open overhead electrical disconnects for KHU associated with the underground power path.

Restore one breaker to OPERABLE status.

AC Sources - Operating 3.8.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AN9

+2 RSl::IFS fFem eliseei.iei=y ef iR013eFaele K:l=lY 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for one unit AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for other unit(s) 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 24 hours (continued) 3.8.1-7 Amendment Nos. 383, 386, & 384

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

HBRSEP Unit No. 2 However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " EXiample 1.3 3 illustrates one use of this type of Completion Time. The 10 day Completion Time speoified for Conditions A and B in EXiample 1.3 3 may not be eXitended.

1.3-2 (continued)

Amendment No. 4-7e

1.3 Completion Times EXAMPLES

( continued)

HBRSEP Unit No. 2 EXAMPLE 1.3-3 ACTIONS CONDITION A. One Function X train inoperable.

B.

One Function Y train inoperable.

C. One Function X train inoperable.

AND One Function Y train inoperable.

REQUIRED ACTION A.1 Restore Function X train to OPERABLE status.

B.1 Restore Function Y train to OPERABLE status.

C.1 Restore Function X train to OPERABLE status.

OR C.2 Restore Function Y train to OPERABLE status 1.3-6 Completion Times 1.3 COMPLETION TIME 7 days ANG

~ Q says fFeFft sissei.iei:y ef faih::1Fe te Ffteet tt:1e bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANG

~ Q says fFeFft sisse*.iei:y ef faih,1Fe te A=teet tRe bGG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Amendment No. 4-7e

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions /\\ and B are modified by a logical connector 1Nith a separate 1 O day Completion Time measured from the time it 11.ias disco1.*ered the LCO was not met. In this example, without the separate Completion Time, it 11.'ould be possible to alternate between Conditions /\\, B, and C in such a manner that operation could continue indefinitely without e*.*er restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from disco*.iery of failure to meet the LCO" is designed to pre*.ient indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition 11.'as entered.

INSERT:

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

HBRSEP Unit No. 2 1.3-7 Amendment No. 47e

3.6 CONTAINMENT SYSTEMS Containment Spray and Cooling Systems 3.6.6 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable.

spray train to OPERABLE status.

AN9

~ Q says fFem siseeYei=y ef failijFe te meet U=ie bGG B.

Required Action and 8.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5.

84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months C.

One containment cooling C.1 Restore containment 7 days train inoperable.

cooling train to OPERABLE status.

AN9

~ Q says fFem siseeYei=y ef failijFe te meetU=ie bGG

( continued)

HBRSEP Unit No. 2 3.6-15 Amendment No. 4-7e

3. 7 PLANT SYSTEMS 3.7.4 Auxiliary Feedwater (AFW) System AFW System 3.7.4 LCO 3.7.4 Four AFW flow paths and three AFW pumps shall be OPERABLE.

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

Only one AFW flow path with one motor driven pump is required to be OPERABLE in MODE 4.

APPLICABILITY:

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

ACTIONS

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

LCO 3.0.4.b is not applicable.

CONDITION A.

OneAFW pump A.1 inoperable in MODE 1, 2, or 3.

OR One or two AFW flow paths inoperable in MODE 1, 2, or 3.

B.

Two motor driven AFW 8.1 pumps inoperable in MODE 1, 2, or 3.

OR Three motor driven AFW flow paths inoperable in MODE 1, 2, or 3.

HBRSEP Unit No. 2 REQUIRED ACTION Restore AFW pump or flow path(s) to OPERABLE status.

Restore one motor driven AFW pump or one flow path to OPERABLE status.

3.7-10 COMPLETION TIME 7 days ANG 8 elays fFeA=I ElisoeveF)' ef foiluFe te A=1eet tl=le bGG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ANG B elays fFeA=I elisoeYeF)' ef failurn te A=1eet tl=le bGG (continued)

Amendment No. ~

ACTIONS (continued)

CONDITION REQUIRED ACTION A.

(continued)

A.3 Restore offsite circuit to OPERABLE status B.

One DG inoperable.

8.1 Perform SR 3.8.1.1 for the offsite circuit.

AND 8.2 Declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.

AND B.3.1 Perform SR 3.8.1.2 for OPERABLE DG OR B.3.2.1 Determine OPERABLE DG is not inoperable due to common cause failure.

AND HBRSEP Unit No. 2 3.8-2 AC Sources-Operating 3.8.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANf)

~ g elays fFeFR eliseeYery ef failuFe ta FReet bGQ 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours (continued)

Amendment No. ~

ACTIONS (continued)

CONDITION REQUIRED ACTION B.

(continued)

NOTE--

Not required to be performed when the cause of the inoperable DG is pre-planned maintenance and testing.

8.3.2.2 Perform SR 3.8.1.2 for OPERABLE DG.

AND 8.4 Restore DG to OPERABLE status.

C.

Two offsite circuits C.1 Declare required inoperable.

feature(s) inoperable when its redundant required feature(s) is inoperable.

AND C.2 Restore one offsite circuit to OPERABLE status.

HBRSEP Unit No. 2 3.8-3 AC Sources-Operating 3.8.1 COMPLETION TIME 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 7 days AN9 rn says fFeffl elisommFy ef failure te

!fleet bGQ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required features 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Amendment No. 2-e+

3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating Distribution Systems-Operating 3.8.9 LCO 3.8.9 Train A and Train B AC, DC, and AC instrument bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One AC electrical power A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem power distribution inoperable.

subsystem to AN9 OPERABLE status.

~ e RSl:IFS fFem diseoyer:y of faill:IFe to meet bGG B.

One AC instrument bus B.1 Restore AC instrument 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem inoperable.

bus subsystem to OPERABLE status.

AN9

~ e ROl:IFS fFOm diseo.. *er:y ef fail1:1rn to meet bGG C.

One DC electrical power C. 1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months distribution subsystem power distribution inoperable.

subsystem to AN9 OPERABLE status.

~ e ROl:IFS fFom disooYer:y of fail1:1rn to meet bGG (continued)

HBRSEP Unit No. 2 3.8-32 Amendment No. 4+e

U.S. Nuclear Regulatory Commission RA-19-0043, Attachment PROPOSED TECHNICAL SPECIFICATION BASES PAGES (For Information Only)

BASES AFW System B 3.7.5 ACTIONS (continued) be applied in this circumstance.

A.1 If one of the two steam supplies to the turbine driven AFW train is inoperable, or if a turbine driven pump is inoperable while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a.

For the inoperability of a steam supply to the turbine driven AFW pump, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump.

b.

For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c.

For both the inoperability of a steam supply line to the turbine driven pump and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps; and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be iAGperable during any continuous failure to meet this LCO.

The 1 O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The ~

connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling.

Condition A allows the turbine driven AFW pump to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

Catawba Units 1 and 2 B 3.7.5-5 Revision No. S

BASES AFW System B 3.7.5 ACTIONS (continued) 8.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on redundant capabilities afforded by the AFW System, time needed for repairs, and the low probability of a DBA occurring during this time period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allo11.1ed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The ~

connector bet\\~.ieen 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 0-days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

C.1 and C.2 When Required Action A.1 or 8.1 cannot be completed within the required Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.

D.1 If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting Catawba Units 1 and 2 B 3.7.5-6 Revision No. 5

BASES ACTIONS ( continued)

AC Sources-Operating B 3.8.1 If at any time during the existence of Condition A (one LCO 3.8.1.a offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1 E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1 E Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

According to Regulatory Guide 1.93 (Ref. 7), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1 E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

The seoond GoR1pletion TiRle for Required /\\otion /\\.3 establishes a liRlit on the R1axiR1UR1 tiRle allowed for any 00R1bination of required /\\G power souroes to be inoperable during any single oontiguous ooourrenoe of failing to Rleet LGO 3.8.1.a or LGO 3.8.1.b. If Condition/\\ is entered while, for instanoe, a LGO 3.8.1.b DG is inoperable and that DG is subsequently returned OPER/\\BLE, the LGO Rlay already have been not Rlet for up to 14 days. This oould lead to a total of 17 days, sinoe initial failure to Rleet LGO 3.8.1.a or LGO 3.8.1.b, to restore the offsite oirouit.

/\\t this tiRle, a DG oould again beooR1e inoperable, the oirouit restored OPER/\\BLE, and an additional 11 days (for a total of 31 days) allo*,.*od Catawba Units 1 and 2 B 3.8.1-8 Revision No. 7

BASES ACTIONS (continued)

AC Sources-Operating B 3.8.1 prior to oomplete restoration of LCOs a.8.1.a and a.8.1.b. The 17 day Completion Time proYides a limit on tho time allo*Ned in a spooifiod oondition after disooYory of failure to meet LCO a.8.1.a or LCO a.8.1.b.

This limit is oonsidered reasonable for situations in,..,hioh Conditions A and B are entered oonourrently. The "~" oonneotor bet\\Yeen the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 17 day Completion Times means that both Completion Times apply simultaneously, and the more rostriotive Completion Time must be met.

As in Required /\\otion /\\.2, the Completion Time allov,*s for an mmeption to the normal "time 2:ero" for beginning tho allowed outage time "olool<."

This will result in establishing the "time 2:ero" at the time that LCO a.8.1.a or LCO a.8.1.b was initially not mot, instead of at the time Condition/\\

was entered.

It is required to administratively verify the LCO 3.8.1.d DG(s) OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to continue this action once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter until restoration of the required LCO 3.8.1.b DG is accomplished. This verification provides assurance that the LCO 3.8.1.d DG is capable of supplying the onsite Class 1 E AC Electrical Power Distribution System.

If one LCO 3.8.1.d DG is discovered to be inoperable when performing the administrative verification of operability, then Condition Dis entered for that DG. If two LCO 3.8.1.d DGs are discovered to be inoperable when performing the administrative verification of operability, then Condition G is entered.

To ensure a highly reliable power source remains with an inoperable LCO 3.8.1.b DG, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

B.3 Required Action B.3 is intended to provide assurance that a loss of offsite power, during the period that a LCO 3.8.1.b DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes Catawba Units 1 and 2 B 3.8.1-9 Revision No. +

BASES ACTIONS (continued)

AC Sources-Operating B 3.8.1 preplanned maintenance (preventive or corrective) or unplanned corrective maintenance work, the Completion Time can be extended from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days if ESPS is verified available for backup operation.

The fourth Completion Time for Required Aetion 8.6 establishes a lirnit on the ma><imum time allowed for any eombination of required AG po*Ner soureos to be inoperable during any single oontiguous ooourrenoe of failing to meet LGO a.8.1.a or LGO a.8.1.b. If Condition Bis entered while, for instanoe, a LGO a.8.1.a offsite oirouit is inoperable and that oirouit is subsequently restored OPERABLE, the LGO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 17 days, sinoe initial failure to meet LGO a.8.1.a or LGO a.8.1.b, to restore the DG.

At this time, a LGO a.8.1.a offsite oirouit oould again beoome inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to oomplete restoration of LGO a.8.1.a and LGO a.8.1.b. The 17 day Completion Time provides a limit on time allowed in a specified condition after discovery of failure to meet LGO a.8.1.a or LGO a.8.1.b. This limit is oonsidered reasonable for situations in whioh Conditions A and B are entered oonourrently. The "8NQ" oonneotor bet\\veen the 14 day and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restriotive Completion Time must be met.

As in Required Aotion B.a, the Completion Time allows for an e><oeption to the normal "time zero" for beginning the allo't*.ied time "olook." This will result in establishing tho "time zero" at the time that LGO a.8.1.a or LGO a.8.1.b was initially not met, instead of at the time Condition B was entered.

C.1 Condition C addresses the inoperability of the LCO 3.8.1.c qualified offsite circuit(s) between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System when the LCO 3.8.1.c qualified offsite circuit(s) is necessary to supply power to the shared systems and NSWS pump(s). If Condition C is entered concurrently with the inoperability of LCO 3.8.1.d DG(s) the NOTE requires the licensed operator to evaluate if the TS 3.8.9 "Distribution Systems - Operating" requirement that "OPERABLE AC electrical power distribution subsystems require the associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages" continues to be met. In the case where the inoperable LCO 3.8.1.c qualified offsite circuit and inoperable LCO 3.8.1.d DG are associated with the same train there is no longer assurance that train of "Distribution Systems - Operating" can be energized to the proper Catawba Units 1 and 2 B 3.8.1-13 Revision No. +

BASES ACTIONS (continued)

AC Sources-Operating B 3.8.1 unavailable ESPS. However, if the ESPS unavailability occurs at or sometime after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of continuous LCO 3.8.1.d DG inoperability, then the remaining time to restore the ESPS to available status or to restore the DG to OPERABLE status is limited to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times allow for an exception to the normal "time zero" for beginning the allowed outage time "clock." The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time only begins on discovery that both:

a. An inoperable DG exists; and

b. ESPS is unavailable.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time only begins on discovery that:

a. An inoperable DG exists for ~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ; and

b. ESPS is unavailable.

Therefore, when one LCO 3.8.1.d DG is inoperable due to either preplanned maintenance (preventive or corrective) or unplanned corrective maintenance work, the Completion Time can be extended from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days if ESPS is verified available for backup operation.

The fourth Completion Time for Required /\\otion D.6 establishes a limit on the maximum time allm\\*ed for any oombination of required /\\C power souroes to be inoperable during any single oontiguous ooourrenoe of failing to meet LCO 3.8.1.o or LCO 3.8.1.d. If Condition Dis entered while, for instanoe, a LCO 3.8.1.o offsite oirouit is inoperable and that oirouit is subsequently restored OPER/\\BLE, the LCO may already haYe been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 17 days, sinoe initial failure to meet LCO 3.8.1.o or LCO 3.8.1.d, to restore the DG.

/\\t this time, a LCO 3.8.1.o offsite oirouit oould again beoome inoperable, the DG restored OPER/\\BLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to oomplete restoration of LCO 3.8.1.o and LCO 3.8.1.d. The 17 day Completion Time pro'f*ides a limit on time allm\\*ed in a speoified oondition after disooYery of failure to meet LCO 3.8.1.o or LCO 3.8.1.d. This limit is oonsidered reasonable for situations in whioh Conditions C and D are entered oonourrently. The "8!::ill" oonneotor between the 14 day and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restriotiYe Completion Time must be met.

E.1 and E.2 Condition Eis entered when both offsite circuits required by LCO 3.8.1.a are inoperable, or when the offsite circuit required by LCO 3.8.1.c and Catawba Units 1 and 2 B 3.8.1-19 Revision No. +

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued) stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a.

The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit; and

b.

The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The second Completion Time for Required Action.A..1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution restored OPERABLE. This could continue indefinitely.

TAe-Gompletion Time allows for an-exception to the normal ~ime zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

B.1 With one AC vital bus inoperable, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition.

Overall reliability is reduced, however, since an additional single failure could result in the minimum ESF functions not being supported.

Therefore, the required AC vital bus must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated inverter via inverted DC or constant voltage transformer.

Catawba Units 1 and 2 B 3.8.9-4 Revision No. 2

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

Condition B represents one AC vital bus without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected vital bus.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital AC power. Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if declared inoperable, is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a OBA occurring during this period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the vital bus distmnmon system. At this time,-an AC train cooki-again become inoperable, and vital bus distribution restored OPERABLE. This could continu~RdeHnitely.

Catawba Units 1 and 2 B 3.8.9-5 Revision No. i

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion

rime is an acceptable limitati00-on this potential to fail to meet the LCO indefinitely.

C.1 With one DC bus inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C represents one DC bus without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining channels and restoring power to the affected channel.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) versus allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected channel; and Catawba Units 1 and 2 B 3.8.9-6 Revision No. 2

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

c.

The potential for an event in conjunction with a single failure of a redundant component.

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed-for-any combinatiGA-Gf-required distributioo subsystems to be inoperable during any single contiguous occurrence of failing to meet-the LCO. If Condition C is entered while, for insta-AG&;--an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

D. 1 With a train of DC inoperable, the remaining DC train is capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The reliability is reduced because a single failure in the remaining train of DC could result in the minimum required ESF functions not being supported. Therefore, the train of DC must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Condition D represents the loss of control power for an entire safety train.

In this situation, the unit is significantly more vulnerable to a complete loss of all DC control power with a corresponding loss of required ESF functions. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining Train of DC and restoring the power to the affected train.

The two hour limit is more conservative than Completion Times allowed for the majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, Catawba Units 1 and 2 B 3.8.9-7 Revision No. i

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued) which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) versus allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for a train of DC is consistent with Regulatory Guide 1.93 (Ref. 4).

The second Completion Time for Required Action D.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable-dw:ir-lg-an-y-siAQle contiguous occw:reAC8--Gf failing to meet--tAe LCO. If Condition D is entered-WA-its, for instance, an AC bus is inoperable and subsequently-1:eturned OPERABLE, the LCO may already have been not met-for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ThiS-GGYld-lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPER.A.BLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This *.viii result in establishing the "time zero" at the time the LCO 1.vas initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

E.1 and E.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this Catawba Units 1 and 2 B 3.8.9-8 Revision No. 2-

BASES AFW System B 3.7.5 ACTIONS (continued) immediately following a refueling, tho 7 day Completion Time is reasonable duo to tho availability of redundant OPERABLE motor driven AFW pumps; and duo to tho low probability of an event requiring tho use of tho turbine driven AFW pump.

The seoond Completion Time for Required /\\otion /\\.1 establishes a limit on tho maximum time allo*wed for any oombination of Conditions to be inoperable during any oontinuous failure to moot this LCO.

Tho 1 O day Completion Time pro*,idos a limitation time allowed in this spooifiod Condition after disooYory of failure to moot the LCO. This limit is oonsidored reasonable for situations in whioh Conditions /\\ and B are entered oonourrontly. The ~

oonneotor bot>.*,oen 7 days and 1 O days diotates that both Completion Times apply simultaneously, and the more restriotiYe must be mot.

Condition A is modified by a Note which limits tho applicability of tho Condition to when tho unit has not entered MODE 2 following a refueling.

Condition A allows tho turbine-driven AFW pump to be inoperable for 7 days vice tho 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to tho reactor being critical.

B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes tho loss of two steam supply lines to tho turbine driven AFW pump. Tho 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on redundant capabilities afforded by tho AFW System, time needed for repairs, and tho low probability of a OBA occurring during this time period.

The sooond Completion Time for Required /\\otion B.1 establishes a limit on tho maximum time allowed for any oombination of Conditions to be inoperable during any oontinuous failure to meet this LCO.

The 1 O day Completion Time proYides a limitation time alloi..*ed in this spooifiod Condition after disooYory of failure to moot tho LCO. This limit is oonsidored reasonable for situations in whioh Conditions /\\ and B are entered oonourrently. Tho ~

oonnootor bot\\*

1oon 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days diotatos that both Completion Times apply simultaneously, and tho more rostriotiYo must be mot.

McGuire Units 1 and 2 B 3.7.5-5 Revision No. 4eG

ACTIONS (continued)

AC Sources-Operating B 3.8.1 According to Regulatory Guide 1.93 (Ref. 7), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1 E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

The seoond Completion Time for Required Aotion A.a establishes a limit on the ma>Eimum time allowed for any oombination of required AG power souroes to be inoperable during any single oontiguous ooourrenoe of failing to meet LGO a.8.1.a or LGO a.8.1.b. If Condition A is entered while, for instanoe, a LGO a.8.1.b DG is inoperable and that DG is subsequently returned OPERABLE, the LGO may already ha'l*e been not met for up to 14 days. This oould lead to a total of 17 days, sinoe initial failure to meet LGO a.8.1.a or LGO a.8.1.b, to restore the offsite oirouit.

At this time, a DG oould again beoome inoperable, the oirouit restored OPl=RABLE, and an additional 14 days (for a total of 31 days) allowed prior to oomplete restoration of LGOs 3.8.1.a and 3.8.1.b. The 17 day Completion Tirne pro'l1ides a limit on the time allowed in a specified condition after disoo'l*ery of failure to meet LGO 3.8.1.a or LGO 3.8.1.b.

This limit is oonsidered reasonable for situations in which Conditions A and B are entered conourrently. The "~" oonneotor bet\\veen the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restriotive Completion Time must be met.

As in Required Aotion A.2, the Completion Time allows for an e>Eoeption to the normal "time 2:ero" for beginning the allowed outage time "olook."

This will result in establishing the "time 2:ero" at the time that LGO 3.8.1.a or LGO 3.8.1.b was initially not met, instead of at the time Condition A was entered.

B.1 It is required to administratively verify the LCO 3.8.1.d DG(s) OPERABLE within one hour and to continue this action once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter until restoration of the required LCO 3.8.1.b DG(s) is accomplished. This verification provides assurance that the LCO 3.8.1.d DG is capable of supplying the onsite Class 1 E AC Electrical Power Distribution System.

McGuire Units 1 and 2 B 3.8.1-10 Revision No. 4e+

ACTIONS (continued)

AC Sources-Operating B 3.8.1 reasonable time for repairs, and the low probability of a OBA occurring during this period.

If the ESPS is or becomes unavailable with an inoperable LCO 3.8.1.b DG, then action is required to restore the ESPS to available status or to restore the DG to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of unavailable ESPS. However, if the ESPS unavailability occurs at or sometime after 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of continuous LCO 3.8.1.b DG inoperability, then the remaining time to restore the ESPS to available status or to restore the DG to OPERABLE status is limited to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times allow for an exception to the normal "time zero" for beginning the allowed outage time "clock." The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time only begins on discovery that both:

a. An inoperable DG exists; and

b. ESPS is unavailable.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time only begins on discovery that:

a. An inoperable DG exists for ~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ; and

b. ESPS is unavailable.

Therefore, when one LCO 3.8.1.b DG is inoperable due to either preplanned maintenance (preventive or corrective) or unplanned corrective maintenance work, the Completion Time can be extended from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days if ESPS is verified available for backup operation.

The fourth Completion Time for Required Aotion B.6 establishes a limit on the mm<imum time allowed for any oombination of required AG power souroes to be inoperable during any single oontiguous ooourrenoe of failing to meet LGO 3.8.1.a or LCO 3.8.1.b. If Condition Bis entered 1*..hile, for instanoe, a LCO 3.8.1.a offsite oirouit is inoperable and that oirouit is subsequently restored OPeRABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 17 days, sinoe initial failure to meet LCO 3.8.1.a or LCO 3.8.1.b, to restore the DG.

At this time, a LGO 3.8.1.a offsite oirouit oould again beoome inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to oomplete restoration of LCO 3.8.1.a and LGO 3.8.1.b. The 17 day Completion Time pro*.iides a limit on time allowed in a speoified oondition after disoo,.*ery of failure to meet LGO 3.8.1.a or LCO 3.8.1.b. This limit is oonsidered reasonable for situations in whioh Conditions A and B are entered oonourrently. The "fil!Q" oonneotor betv.ieen the 14 day and 17 day Completion Times means that both Completion Times apply simultaneously, and the more restriotive Completion Time must be met.

McGuire Units 1 and 2 B 3.8.1-14 Revision No. 4e7

ACTIONS (continued)

AC Sources-Operating B 3.8.1 As in Required ft.otion B.a, the Completion Time allows for an mmeption to the normal "time 2:ero" for beginning the allowed time "olook." This will result in establishing the "time 2:ero" at the time that LCO a.8.1.a or LCO a.8.1.b was initially not met, instead of at the time Condition B,.,,as entered.

C.1 Condition C addresses the inoperability of the LCO 3.8.1.c qualified offsite circuit(s) between the offsite transmission network and the opposite unit's Onsite Essential Auxiliary Power System when the LCO 3.8.1.c qualified offsite circuit(s) is necessary to supply power to the shared systems. If Condition C is entered concurrently with the inoperability of LCO 3.8.1.d DG(s) the NOTE requires the licensed operator to evaluate if the TS 3.8.9 "Distribution Systems - Operating" requirement that "OPERABLE AC electrical power distribution subsystems require the associated buses, load centers, motor control centers, and distribution panels to be energized to their proper voltages" continues to be met. In the case where the inoperable LCO 3.8.1.c qualified offsite circuit and inoperable LCO 3.8.1.d DG are associated with the same train there is no longer assurance that train of "Distribution Systems - Operating" can be energized to the proper voltage and therefore TS 3.8.9 Condition A must be entered.

To ensure a highly reliable power source remains with one required LCO 3.8.1.c offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition A and E, as applicable, for the two offsite circuits inoperable, is entered.

Required Action C.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function for the NSWS, CRAVS, CRACWS or the ABFVES. The Completion Time for Required Action C.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

The train has no offsite power supplying its loads; and McGuire Units 1 and 2 83.8.1-15 Revision No. e+

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

The second Completion Time for Required Action.A.. 1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered 1.1,1hile, for instance, a OC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the,A,C distribution system. At this time, a OC circuit could again become inoperable, and AC distribution restored OPERABLE. This could COAm:lYe4ndeunitety.,

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This 11.iill result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

B.1 With one AC vital bus inoperable, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum ESF functions not being supported. Therefore, the required AC vital bus must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated inverter via inverted DC or regulated voltage transformer.

Condition B represents one AC vital bus without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected vital bus.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital AC power. Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if declared inoperable, is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue; McGuire Units 1 and 2 B 3.8.9-4 Revision No. -145

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

b.

The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The sewnd Completion Time for Required Action B.1 establishes a limit on the maximum allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered \\\\1hile, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the vital bus distributioo system. At this time, an AC train could again become inoperable, and-V-itat bus distribution restored OPERABLE. This could continue indefinitely.

This Completion Time aUows for an exception to the normal "time zero" for beginning the allov1ed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

With one DC bus in one train inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

McGuire Units 1 and 2 B 3.8.9-5 Revision No. -145

BASES Distribution Systems-Operating B 3.8.9 ACTIONS (continued)

Condition C represents one DC bus without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining channels and restoring power to the affected channel.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected channel; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 4).

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable-aAd subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 1 O hours, since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERABLE. This-CGU-ld continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO 1.Yas initially not met, instead of the time Condition C 1Nas entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

McGuire Units 1 and 2 B 3.8.9-6 Revision No. +-1-5

BASES ACTIONS (continued)

A.1 Reactor Building Spray and Cooling Systems B 3.6.5 With one reactor building spray train inoperable in MODE 1 or 2, the inoperable reactor building spray train must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The 7 day Completion Time takes into account the redundant heat removal capability afforded by the OPERABLE reactor building spray train, reasonable time for repairs, and the low probability of an accident occurring during this period.

The 14 day portion of the Completion Time for Required Aotion A.1 is based upon engineering judgment. It takes into aooount the low probability of ooinoident entF)1 into t\\*.io Conditions in tt:iis LCO ooupled 11t1itt:i the low probability of an aooident ooourring during tt:iis time. Refer to Seotion 1.3, Completion Times, for a rnore detailed disoussion of the purpose of the "from disoovery of failure to meet tt:ie LCO" portion of the Completion Time.

B.1 With one of the reactor building cooling trains inoperable in MODE 1 or 2, the inoperable reactor building cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Reactor Building Spray System and Reactor Building Cooling System and the low probability of an accident occurring during this period.

The 14 day portion of tt:ie Completion Time for Required Aotion B.1 is based upon engineering judgment. It takes into aooount tt:ie low probability of ooinoident entry into two Conditions in tt:iis LCO ooupled with tt:ie low probability of an aeoident ooourring during tt:iis time. Refer to Seotion 1.3 for a rnore detailed disoussion of tt:io purpose of tho "from disoovory of failure to moot tt:ie LCO" portion of the Completion Time.

C.1 With one reactor building spray train and one reactor building cooling train inoperable in MODE 1 or 2, at least one of the inoperable trains must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In this Condition, the remaining OPERABLE spray and cooling trains are adequate to provide iodine removal capabilities and are capable of providing at least 100% of OCONEE UNITS 1, 2, & 3 B 3.6.5-6 Rev.GW

BASES ACTIONS A.1

( continued)

EFW System B 3.7.5

c.

The low probability of an event occurring that would require the EFW System during the 7 day period.

The seoond Completion Time for Required /\\otion /\\.1 establishes a limit on the maximum time allo1_..ied for any oombination of Conditions to be inoperable during any oontinuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allo*Ned in this speoified Condition after disoo\\1ery of failure to meet the LCO. This limit is oonsidered reasonable for situations in whioh Conditions /\\ and B exist oonourrently. The~ oonneotor between 7 days and 10 days diotates that both Completion Times apply simultaneously, and the more restriotive must be met.

8.1 When the turbine driven EFW pump or one EFW flow path is inoperable, action must be taken to restore the pump and flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the EFW System, time needed for repairs, and the low probability of an accident occurring during this time period. The seoond Completion Time for Required /\\otion B.1 establishes a limit on the maximum time alloi.*Jed for any oombination of Conditions to be inoperable during any oontinuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allowed in this speoified Condition after disoo*,ery of failure to meet the LCO. This limit is oonsidered reasonable for situations in *..<hioh Conditions /\\ and B exist oonourrently. The~ oonneotor between 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 10 days diotates that both Completion Times apply simultaneously, and the more restriotive must be met.

C.1 With the two motor driven EFW pumps inoperable, action must be taken to restore at least one pump to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on the redundant capabilities afforded by the turbine driven EFW pump, time needed for repairs, and the low probability of an accident occurring during this time period.

OCONEE UNITS 1, 2, & 3 B 3.7.5-4 Rev.~

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

If the inoperable KHU or its required overhead emergency power path are not restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months as required by Required Action C.2.1, a controlled shutdown must be initiated as required by the Required Actions for Condition M unless the extended Completion Times of Required Action C.2.2.5 are applicable. The sooond Completion Time for Required Aotion C.2.1 establishes a limit on the maiEimum time allowed for a KHU to be inoperable during any single oontiguous ooourrenoe of having a KHU inoperable. If Condition C is entered as a result of switohing an inoperable KHU from the underground to the overhead emergenoy po,-*.ier path, it may hm*e been inoperable for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 14 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sinoe the initial failure of the KrlU. The sooond Completion Time allows for an mmeption to the normal "time z:ero" for beginning the allmved time "olool<." This will result in establishing the "time z:ero" at the time the KHU beoome inoperable, instead of at the time Condition C was entered.

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

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

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

Required Action C.2.2.5 also permits maintenance and repair of a KHU which requires longer than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The primary long term maintenance items are expected to be hydro turbine runner and discharge ring welding OCONEE UNITS 1, 2, & 3 B 3.8.1-9 Rev. 008

BASES ACTIONS D.1, D.2 and D.3 (continued)

AC Sources - Operating B 3.8.1 demonstration is to assure that the remaining emergency power path is not inoperable due to a common cause or due to an undetected failure.

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

The seoond Completion Time for Required Aotion D.3 establishes a limit on the maximum time allm\\led for a KHU to be inoperable during any single oontiguous ooourrenoe of ha*.iing a KHU inoperable. If Condition D is entered as a result of switohing an inoperable KHU from the overhead to the underground emergenoy power path, it may have been inoperable for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 14 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sinoe the initial failure ofthe KHU. The seoond Completion Time allo1t\\'S for an exoeption to the normal "time 2:ero" for beginning the allowed time "olool<." This *..<ill result in establishing the "time 2:ero" at the time the KHU beoome inoperable, instead of at the time Condition D was entered.

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

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

OCONEE UNITS 1, 2, & 3 83.8.1-13 Rev.OOe

BASES ACTIONS HBRSEP Unit No. 2 A.1 (continued)

Containment Spray and Cooling Systems B 3.6.6 removal capability afforded by the Containment Spray System and Containment Cooling System, reasonable time for repairs, and low probability of a OBA occurring during this period.

The 10 day portion of the Completion Time for Required Aotion A.1 is based upon engineering judgment It takes into aooount the ID\\\\'

probability of ooinoident entry into Pl.'O Conditions in this Speoifioation ooupled..... ith the low probability of an aooident ooourring during this time.

Ref.er to Seotion 1.a, "Completion Times," for a more detailed disoussion of the purpose of the "from disoo\\'ery of failure to meet the LCO" portion of the Completion Time.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time for attempting restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

C. 1 With one of the containment cooling trains inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. In this degraded condition at least one train of containment spray and the remaining containment cooling train are capable of providing at least 100% of the heat removal needs. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and (continued)

B 3.6-38 Revision No. ~

BASES ACTIONS HBRSEP Unit No. 2 C.1 (continued)

Containment Spray and Cooling Systems B 3.6.6 Containment Cooling System and the low probability of DBA occurring during this period.

The 1 O day portion of the Completion Time for Required Aotion C.1 is based upon engineering judgment. It takes into aooount the lo*.-.*

probability of ooinoident entry into two Conditions in this Speoifioation ooupled with the low probability of an aooident ooourring during this time.

Refer to Seotion 1.a for a more detailed disoussion of the purpose of the "from disooYery of failure to meet the LCO" portion of the Completion Time-:

D.1 With two containment cooling trains inoperable, one of the containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this degraded condition the containment spray trains are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of DBA occurring during this period.

E.1 and E.2 If the Required Action and associated Completion Time of Condition C or D of this LCO are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

B 3.6-39 Revision No. O

BASES ACTIONS HBRSEP Unit No. 2 A.1 (continued)

AFW System B 3.7.4 The second Completion Time for Required Action A.1 establishes a limit on the ma>Eimum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 8 day Completion Time provides a limitation time allowed in this specified Condition after disco*,*ery of failure to meet the LCO. This limit is considered reasonable for situations in v,*hioh Conditions A and B are entered oonourrently. The 8NQ oonneotor bet\\veen 7 days and 8 days diotates that both Completion Times apply simultaneously, and the more restrioti1.'e must be met.

(continued)

B 3.7-25a Revision No. ~

BASES AFW System B 3.7.4 ACTIONS B.1 (continued)

HBRSEP Unit No. 2 With two motor driven AFW pumps inoperable or three motor driven AFW flow paths inoperable, a diverse and redundant means of supplying AFW to the three steam generators is lost. The steam driven AFW pump and flow path remains in service to provide injection capability to all three steam generators. Action must be taken to restore one inoperable motor driven AFW pump or flow path to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable, based on the remaining capabilities afforded by the AFW System, time needed for repairs, and the low probability of a OBA occurring during this time period.

The seoond Completion Time for Required /\\otion B.1 establishes a limit on the maximum time allowed for any oombination of Conditions to be inoperable during any oontinuous failure to meet this LCO.

The 8 day Completion Time provides a limitation time allowed in this speoified Condition after disooveF)1 of failure to meet the LCO. This limit is oonsidered reasonable for situations in whioh Conditions /\\ and B are entered oonourrently. The 8.t!Q oonneotor between 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 8 days dictates that both Completion Times apply simultaneously, and the more restrioti*;e must be met.

C.1 and C.2 When Required Action A.1 or B.1 cannot be completed within the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.

( continued)

B 3.7-26 Revision No. Q

BASES ACTIONS (continued)

HBRSEP Unit No. 2 AC Sources - Operating B 3.8.1 Discovering no offsite power to one train of the onsite emergency Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite emergency Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

According to Regulatory Guide 1.93 (Ref. 9), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite emergency Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

The seoond Completion Time for Required l'.otion l'..a establishes a limit on the ma>Eimum time allowed for any oombination of required 1'.C power souroes to be inoperable during any single oontiguous ooourrenee of failing to meet the LCO. If Condition I'. is entered while, for instanoe, a DG is inoperable and that DG is subsequently returned OPERl'.BLE, the LCO may already hatJe been not met for up to 7 days. This oould lead to a total of 1 O days, sinoe initial failure to meet the LCO, to restore the offsite oirouit.

l'.t this time, a DG oould again beoome inoperable, the oireuit restored OPERABLE, and an additional 7 days (fur a total of 17 days) allo't\\1ed prior to oomplete restoration of the LCO. The 10 day Completion Time pro¥ides a limit on the time allowed in a speoified oondition after disoo¥eF)' of failure to meet the LCO.

(continued)

B 3.8-7 Revision No. 79

BASES ACTIONS (continued)

Times HBRSEP Unit No. 2 AC Sources - Operating B 3.8.1 This limit is oonsidered reasonable for situations in whioh Conditions /\\

and 8 are entered oonourrently. The "hNQ" oonneotor between the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 1 O day Completion Times means that both Completion apply simultaneously, and the more restriotive Completion Time must be met-:-

The Completion Time allo*,*.is for an mmeption to the normal "time 2:ero" for beginning the allowed outage time "sleek." This will result in establishing the "time 2:ero" at the time that the LCO 1Nas initially not met, instead of at the time Condition/\\ was entered.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

An inoperable DG exists; and (continued)

B 3.8-8 Revision No. -79

BASES ACTIONS (continued)

HBRSEP Unit No. 2 AC Sources - Operating B 3.8.1 In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 6), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

Operation may continue in Condition B for a period that should not exceed 7 days.

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Distribution System. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a OBA occurring during this period.

The seoond Colflpletion Tiffie for Required Aotion B.4 establishes a lilflit on the ffia>EilflUffi tilfle allowed for any oolflbination of required /\\C power sou roes to be inoperable during any single oontiguous ooourrenoe of failing to !fleet he LCO. If Condition B is entered while, for instanoe, an offsite oirouit is inoperable and that oirouit is subsequently restored OPERABLE, the LCO may already have been not lflet for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This oould lead to a total of 1 O days, sinoe initial failure to !fleet the LCO, to restore the DG. At this time, an offsite oirouit oould again beooffie inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 1 a days) allowed prior to oolflplete restoration of the LCO. The 1 O day Colflpletion Time proYides a lilflit on tilfle allowed in a speoified oondition after discoYel)' of failure to !fleet the LCO. This lilflit is considered reasonable for situations in whioh Conditions A and B are entered oonourrently. The

"~" oonneotor between the 7 day and 10 day Colflpletion Tilfles !fleans that both Colflpletion Tilfles apply silflultaneously, and the ffiOre restrioti'41e Colflpletion Tiffie ffiUSt be ffiet.

As in Required Aotion B.2, the Colflpletion Time allows for an e>Eoeption to the norlflal "tilfle 2ero" for beginning the allowed tilfle "olook." This will result in establishing the "tilfle 2ero" at the tilfle that the LCO i.*1as initially not ffiet, instead of at the tilfle Condition B was entered.

(continued)

B 3.8-11 Revision No. 79

BASES ACTIONS HBRSEP Unit No. 2 A.1 (continued)

Distribution Systems - Operating B 3.8.9 supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single active failure. The overall reliability is reduced, however, because a single active failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported.

Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a.

The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit; and

b.

The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LGO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently restored OPER/\\BLE, the LGO may already ha\\1e been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 1 O hours, since initial failure of the LGO, to restore the AG distribution system. At this time, a DC circuit could again become inoperable, and AG distribution restored OPERABLE. This could continue indefinitely.

(continued)

B 3.8-74 Revision No. +9

BASES ACTIONS HBRSEP Unit No. 2 M (oontinued)

Distribution Systems - Operating B 3.8.9 The Completion Time allows for an exoeption to the normal "time 2ero" for beginning the allowed outage time "olook." This will result in establishing the "time 2:ero" at the time the LCO was initially not met, instead of the time Condition /\\ was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an aooeptable limitation on this potential to fail to meet the LCO indefinitely.

With one AC instrument bus subsystem inoperable, the remaining OPERABLE AC instrument buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC instrument bus must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated alternate AC supply.

Condition B represents one AC instrument bus without power; potentially both the DC source or the constant voltage transformer and the associated alternate AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining instrument buses and restoring power to the affected instrument bus.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate instrument AC power. Taking exception to LCO 3.0.2 for components without adequate instrument AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if declared inoperable, is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue; (continued)

B 3.8-75 Revision No. 79

BASES ACTIONS HBRSEP Unit No. 2 B.1 (continued)

Distribution Systems - Operating B 3.8.9

b.

The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate instrument AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC instrument bus to OPERABLE status, the redundant capability afforded by the other OPERABLE instrument buses, and the low probability of a OBA occurring during this period.

The seoond Completion Time for Required Aotion 8.1 establishes a limit on the maximum allowed for any oombination of required distribution subsystems to be inoperable during any single oontiguous ooourrenoe of failing to meet the LCO. If Condition B is entered while, for instanoe, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already ha*.<<e been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This oould lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , sinoe initial failure of the LCO, to restore the instrument bus distribution system. At this time, an AC train oould again beoome inoperable, and instrument bus distribution restored OPERABLE. This oould oontinue indefinitely.

This Completion Time allows for an exoeption to the normal "time zero" for beginning the allowed outage time "olook." This will result in establishing the "time zero" at the time the LCO '#as initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an aooeptable limitation on this potential to fail to meet the LCO indefinitely.

C. 1 With DC bus(es) in one train inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall

( continued)

B 3.8-76 Revision No. +9

BASES ACTIONS HBRSEP Unit No. 2 C.1 ( continued)

Distribution Systems - Operating B 3.8.9 reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C represents one train without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 4). The seoond Gornpletion Tirne for Required

.l\\otion G.1 estaBlishes a limit on the ma>Eimurn time allowed for any oomBination of required distriBution suBsysterns to BO inoperaBle during any single oontiguous ooourrenoe of failing to rneet the LGO. If Condition C is entered 11t*hile, for instanoe, an.I\\G BUS is inoperaBle and subsequently returned OPER.I\\BLE, the LGO rnay already have (continued)

B 3.8-77 Revision No. 79

BASES ACTIONS HBRSEP Unit No. 2 C.1 ( continued)

Distribution Systems - Operating B 3.8.9 been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 1 O hours, sinoe initial failure of the LCO, to restore the DC distribution system. At this time, an AC train oould again beoome inoperable, and DC distribution restored OPERABLE. This oould oontinue indefinitely.

This Completion Time allows for an mcoeption to the normal "time 2:ero" for beginning the allo*.ved outage time "olook." This 'Nill result in establishing the "time 2:ero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an aooeptable limitation on this potential to fail to meet the LCO indefinitely.

D.1 and E.1 With trip elements of both molded case circuit breakers associated with either the Aux. Feedwater Header Discharge Valve to SIG "A", V2-16A or the Service Water Turbine Building Supply Valve (emergency supply),

V16-16C inoperable, the potential exist that a single failure could adversely affect both trains of the AC Distribution System. For this to occur, a trip element for both of the breakers associated with one valve (one connected to each train of the AC Distribution System) would have to fail. Therefore, one of the associated molded case circuit breaker(s) for each affected valve must be placed in the open position.

Engineering judgment and operating experience indicates that two hours is adequate time to open the affected circuit breaker(s). The two hour Completion Time take into account the importance to safety of opening the affected circuit breakers, the low probability of inoperability of a trip element for both circuit breakers concurrent with a fault on the associated circuit and the low probability of a OBA occurring during this period.

With the affected circuit breaker(s) open, normal or alternate AC power is not available to the associated valve. This Note ensures appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by the removal of the power source(s) from the associated valve.

(continued)

B 3.8-78 Revision No. 79

v t e Letter Sequence Request
EPID:L-2021-LLA-0111, TSTF-439 (Approved, Closed)
Initiation Request Acceptance... Supplement Administration Questions Answers Results Approval Other: ML21200A158
MONTHYEAR2021-07-16 [Table View]

RA-19-0043, Duke Energy - Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

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RA-19-0043, Duke Energy - Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

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