View source for ONS-2014-020, Oconee, Units 1, 2 and 3 - License Amendment Request to Remove Obsolete Information from Technical Specifications, Delete Surveillance Requirements That Equipment Design Cannot Support and Correct a Non-Conservative Condition Statement,

{{Adams
| number = ML14141A415
| issue date = 05/20/2014
| title = Oconee, Units 1, 2 and 3 - License Amendment Request to Remove Obsolete Information from Technical Specifications, Delete Surveillance Requirements That Equipment Design Cannot Support and Correct a Non-Conservative Condition Statement, LAR
| author name = Batson S L
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000269, 05000270, 05000287
| license number = DPR-038, DPR-047, DPR-055
| contact person = 
| case reference number = ONS-2014-020
| document type = Letter type:ONS, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 49
}}

=Text=
{{#Wiki_filter:_J StDUKE L. Batson Vice President ENERGY, Oconee Nuclear Station Duke Energy ONOIVP I 7800 Rochester Hwy Seneca, SC 29672 o: 864.873.3274 f 864.873.4208 ONS-2014-020 Scott.Batson@duke-energy.com 10 CFR 50.90 May 20, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20582-2746

==Subject:==
Duke Energy Carolinas, LLC (Duke Energy)Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 Renewed License Nos. DPR-38, DPR-47, and DPR-55 License Amendment Request to Remove Obsolete Information from Technical Specifications, Delete Surveillance Requirements That Equipment Design Cannot Support and Correct a Non-Conservative Condition Statement License Amendment Request No. 2013-05 In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Duke Energy is submitting a request for an amendment to the Technical Specifications for ONS, Units 1, 2, and 3. The proposed amendment requests removal of Technical Specification requirements for ONS units that did not have the Reactor Protection System (RPS)/Engineered Safeguards Protective System (ESPS) digital upgrades or Low Pressure Service Water (LPSW) Reactor Building (RB) Waterhammer Prevention System (WPS) modifications.
These Technical Specification requirements no longer pertain to ONS since the RPS/ESPS digital upgrade and the LPSW RB WPS modification have been implemented for all three ONS units. The proposed amendment also deletes a Note statement for the Emergency Condenser Circulating Water (ECCW) System Technical Specification that states the Technical Specification is not applicable until after completion of the Service Water upgrade modifications on each respective ONS unit. The Service Water upgrade modifications have been implemented for each ONS unit. Duke Energy considers removal of this obsolete information from the Technical Specifications as an administrative change.In addition, the proposed amendment deletes Surveillance Requirements that are not applicable to one RPS function and to one ESPS function due to associated equipment design. Finally, the proposed amendment corrects a wording error contained in Condition C of Technical Specification 3.7.7, Low Pressure Service Water (LPSW) System.The Enclosure to this letter provides an evaluation of the proposed Technical Specification changes. Regulatory evaluation (including the significant hazards consideration) and environmental considerations are provided in Sections 5 and 6 of the enclosure, respectively.
Attachment 1 provides marked-up Technical Specification pages indicating the proposed www.duke-energy.com 0c~
L.S. Nuclear Regulatory Commission May 20, 2014 Page 2 changes. Attachment 2 provides retyped Technical Specification pages with the proposed changes incorporated.
In accordance with Duke Energy administrative procedures that implement the Quality Assurance Program Topical Report, these proposed changes have been reviewed and approved by the Plant Operations Review Committee.
Duke Energy requests approval of this amendment request by May 20, 2015. Once the amendment request is approved, the amendment will be implemented within 60 days. Duke Energy will also update applicable sections of the ONS Updated Final Safety Analysis Report (UFSAR), as necessary, and submit the updated UFSAR sections in accordance with 10 CFR 50.71(e).
There are no new regulatory commitments being made as a result of the proposed change.If there are any questions regarding the content of this document or if additional information is needed, please contact Sandra Severance, Regulatory Affairs Group, Oconee Nuclear Station, at (864) 873-3466.I declare under penalty of perjury that the foregoing is correct and true. Executed on the 20th day of May, 2014.Sincerely, Scott L. Batson Site Vice President Oconee Nuclear Station 

==Enclosure:==

Evaluation of the Proposed Changes Attachments:
1 Marked-Up Technical Specification Pages 2 Retyped Technical Specification Pages LIU.S. Nuclear Regulatory Commission May 20, 2014 Page 3 cc w/enclosure and attachments:
Mr. Victor McCree Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James R. Hall Senior Project Manager (by electronic mail only)U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 11555 Rockville Pike Mail Stop O-8B1 Rockville, MD 20852-2746 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Ms. Susan E. Jenkins, Manager, Infectious and Radioactive Waste Management Division of Waste Management South Carolina Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201 License Amendment Request No. 2013-05 ENCLOSURE EVALUATION OF THE PROPOSED CHANGES LICENSE AMENDMENT REQUEST NO. 2013-05 

==Subject:==
License Amendment Request to Remove Obsolete Information from Technical Specifications Pertaining to RPS/ESPS Digital Upgrade, LPSW RB WPS Modification, and ECCW System Upgrade Modification 1 

==SUMMARY==
DESCRIPTION 2 BACKGROUND 3 DETAILED DESCRIPTION OF PROPOSED CHANGES 4 TECHNICAL EVALUATION 5 REGULATORY EVALUATION

===5.1 Applicable===

Regulatory Requirements/Criteria

===5.2 Precedent===
5.3 No Significant Hazards Consideration Determination

===5.4 Conclusions===
6 ENVIRONMENTAL CONSIDERATION 7 REFERENCES Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 1 of 13 1 

==SUMMARY==
DESCRIPTION The proposed amendment would revise the Oconee Nuclear Station (ONS) Units 1, 2, and 3 Technical Specifications (TSs) for three distinct reasons. First, the amendment requests removal of obsolete information pertaining to:* Reactor Protective System (RPS)/Engineered Safeguards Protective System (ESPS) digital upgrades,* Low Pressure Service Water (LPSW) System Reactor Building (RB) Waterhammer Prevention System (WPS) modifications, and" Emergency Condenser Circulating Water (ECCW) System Service Water upgrade modifications.
The current ONS Technical Specifications contain requirements for ONS unit(s) that have the RPS/ESPS digital upgrade installed and for ONS unit(s) that do not have the RPS/ESPS digital upgrade installed.
Similarly, Technical Specification requirements exist for ONS unit(s) that have the LPSW RB WPS modification installed and for ONS unit(s) that do not have the LPSW RB WPS modification installed.
In addition, the Technical Specifications for the ECCW System contain a Note indicating that the Technical Specifications only apply after completion of the Service Water upgrade modifications on the respective ONS unit. However, all of these modifications have been implemented on all three ONS units. Thus, the Technical Specification requirements that pertain to ONS unit(s)without the modifications installed no longer apply and should be removed to eliminate potential confusion.
Secondly, the proposed amendment eliminates the Surveillance Requirements (SRs) to manually verify correct software set points for RPS Reactor Building (RB) High Pressure trips (i.e., SR 3.3.1.5) and ESPS RB Pressure -High High actuations (i.e., SR 3.3.5.2)since the RPS trip and ESPS actuation trigger off of pressure switches and have no software set points to verify.Thirdly, Condition C of TS 3.7.7, "Low Pressure Service Water (LPSW) System," states"Required Action and associated Completion Time of Condition A and B not met." However, the word "and" between "A" and "B" is incorrect and should instead be the word"or." Thus, the word "and" is changed to "or' in this Condition statement for TS 3.7.7.The specific Technical Specifications affected by this proposed amendment are as follows: For RPS/ESPS Digital Upgrade* TS 3.3.1, "Reactor Protective System (RPS) Instrumentation;"* TS 3.3.3, "Reactor Protective System (RPS) -Reactor Trip Component (RTC);"* TS 3.3.5, "Engineered Safeguards Protective System (ESPS) Input Instrumentation;" and* TS 3.3.7, "Engineered Safeguards Protective System (ESPS) Automatic Actuation Output Logic Channels." For LPSW RB WPS Modification
* TS 3.3.27, "Low Pressure Service Water (LPSW) Reactor Building (RB)Waterhammer Prevention Circuitry;"* TS 3.6.5, "Reactor Building Spray and Cooling Systems;" and* TS 3.7.7, "Low Pressure Service Water (LPSW) System."
E'nclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 2 of 13 For ECCW System Service Water Upgrade Modification Note* TS 3.7.8, "Emergency Condenser Circulating Water (ECCW) System." For Reactor Building High Pressure Trip and ESPS Reactor Building Pressure -High High Actuation Set Point Verification SR Deletion* TS 3.3.1, "Reactor Protective System (RPS) Instrumentation;" and* TS 3.3.5, "Engineered Safeguards Protective System (ESPS) Input Instrumentation." For LPSW System Condition C Statement* TS 3.7.7, "Low Pressure Service Water (LPSW) System." A detailed description of the proposed changes is provided in Section 3. An evaluation of the proposed changes is provided in Section 4. The marked-up Technical Specification pages associated with this license amendment request are provided in Attachment 1.Retyped Technical Specification pages are provided in Attachment 2.Once this amendment request is approved, the amendment will be implemented within 60 days. There are no new regulatory commitments being made as a result of this proposed change.2 BACKGROUND RPS/ESPS Di-gital Upgrade Duke Energy replaced the analog-based RPS and ESPS at ONS with a TELEPERM XS (TXS) digital protection system. Since the design change was implemented on one ONS unit at a time and since ONS has a single set of Technical Specifications (TSs) that applies to all three ONS units, a change to TS requirements was necessary to accommodate the different equipment designs. ONS License Amendment Request (LAR) No. 2007-09 (Ref.1) was submitted in January 2008 to modify TS requirements so as to specify analog-based RPS/ESPS requirements and digital-based RPS/ESPS requirements.
The NRC approved the license amendment request by issuing Amendments Nos. 366, 368, and 367 to ONS Units 1, 2, and 3 Renewed Facility Operating Licenses, respectively, in January 2010 (Ref. 2).The RPS/ESPS digital upgrade was implemented for each ONS unit during recent refueling outages (RFOs), with the final upgrade occurring on ONS Unit 2 during the Fall 2013 RFO.Thus, the TS requirements for the analog-based RPS/ESPS equipment no longer apply at ONS and are considered extraneous information.
LPSW RB WPS Modification Duke Energy installed a Waterhammer Prevention System (WPS) modification on the LPSW System reactor building (RB) piping. The LPSW RB WPS is composed of check valves, active pneumatic discharge isolation valves, and active controllable vacuum breaker valves.These valves are controlled by LPSW RB Waterhammer Prevention Circuitry.
Similar to the installation method utilized for the RPS/ESPS digital upgrade, the LPSW RB WPS (including LPSW RB Waterhammer Prevention Circuitry) was installed on a staggered basis during RFOs. Since the ONS TSs apply to all three ONS units, the new LPSW RB WPS and LPSW RB Waterhammer Prevention Circuitry TS requirements needed clarification statements and notes to indicate that they only applied if the LPSW RB WPS modification E~nclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 3 of 13 was installed.
Duke Energy submitted ONS LAR No. 2006-05 (Ref. 3) for the new LPSW RB WPS and LPSW RB Waterhammer Prevention Circuitry TS requirements in October 2007. The NRC subsequently approved the license amendment request by issuance of Amendments Nos. 363, 365, and 364 to ONS Units 1, 2, and 3 Renewed Facility Operating Licenses, respectively, in October 2008 (Ref. 4).The LPSW RB WPS and LPSW RB Waterhammer Prevention Circuitry modifications have been installed on all three ONS units. Thus, the associated TS clarification statements and notes for the LPSW RB WPS and LPSW RB Waterhammer Prevention Circuitry modifications no longer apply and are considered extraneous information.
ECCW System Upgrade Modification In December 1995, Duke Energy notified the NRC (Ref. 5) of proposed upgrades to the existing ECCW System by installing a new Essential Siphon Vacuum (ESV) System, a new Siphon Seal Water (SS") System, and to reclassify portions of the Circulating Cooling Water (CCW) System to Quality Assurance (QA) Condition 
: 1. The purpose of these Service Water upgrade modifications was to eliminate reliance on existing non-QA Condition systems and equipment, including the CCW pumps and the High Pressure Service Water (HPSW) System, after a loss of coolant accident with loss of off-site power (LOCA/LOOP).
Duke Energy submitted ONS LAR No. 1996-09 (Ref. 6) in August 1997 to implement the Service Water upgrades into the Technical Specifications.
At the time of the submittal, the Service Water upgrade modifications were not yet implemented, but modification implementation was planned for each ONS unit. Since upgrade modifications would be implemented on a per-unit bases, the submitted LAR was developed with an applicability Note indicating that the revised Technical Specifications would apply only to units with the Service Water upgrade modification completed.
The NRC approved the LAR by issuing Amendments Nos. 229, 230, and 226 to ONS Units 1, 2, and 3 Facility Operating Licenses, respectively, in April 1998 (Ref. 7).The Service Water upgrade modifications were subsequently completed for each ONS unit.Thus, the revised TS requirements for the ECCW System now apply to each ONS unit and the Service Water Upgrade Modification applicability note no longer applies and is considered extraneous information.
RPS RB High Pressure Trip and ESPS RB Pressure -High High Actuation Set Point Verification Surveillance Requirement Deletion Technical Specification Surveillance Requirements SR 3.3.1.5 and SR 3.3.5.2 for the digitally-upgraded RPS and ESPS, respectively, require manual verification that parameters/
functions in these instrumentation systems trip at the proper set points. The intent of these Surveillance Requirements is to retrieve the set points from software periodically to confirm that they have not been incorrectly entered.The ONS Technical Specifications are written such that these Surveillance Requirements apply to all functions of the RPS and to all parameters of the ESPS. However, the RB High Pressure trip function for the RPS and RB Pressure -High-High actuation parameter for the ESPS (which actuates ESPS Channels 7 and 8) have no software set points associated with them. For every other parameter/function associated with both the RPS and the ESPS, there is some value(s) in the software which can be assessed to satisfy the Surveillance Requirement (even for other functions which involve pressure switches).
For the RPS RB High Pressure trip function (i.e., RPS Function No. 6 on TS Table 3.3.1-1) and ESPS RB Pressure -High-High actuation parameter (i.e., ESPS Parameter No. 4 on TS Table Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 4 of 13 3.3.5-1), there is nothing in software to assess since the trip function/actuation parameter consists of pressure switches which only provide contact status to the system. Currently, ONS Technical Specification Bases B 3.3.1 and B 3.3.5 contain a clarification statement in the description sections of SR 3.3.1.5 and SR 3.3.5.2, respectively, that states the SR is not applicable to the trip function/actuation parameter since there is nothing to verify.LPSW System Condition C Statement On October 16, 2007, Duke Energy submitted ONS LAR No. 2006-05 (Ref. 8) for the addition of the LPSW RB WPS modification to mitigate waterhammers described in Generic Letter 96-06. In response to NRC requests for additional information on this LAR submittal, and issues raised in subsequent conversations with the NRC, Duke Energy submitted a revised LAR (Ref. 9) to the NRC on October 23, 2008, which included a new Condition C for TS 3.7.7, "Low Pressure Service Water (LPSW) System." However, the revised LAR inadvertently included the wording error described in Section 1 in new TS 3.7.7 Condition C.The TS 3.7.7 Bases provided with the revised LAR did not reflect the wording error and is correct as stated. The NRC subsequently approved the revised LAR by issuing Amendments Nos. 363, 365, and 364 (Ref. 10) on October 29, 2008. The NRC-issued Amendments also contained the wording error in TS 3.7.7 Condition C.3 DETAILED DESCRIPTION OF PROPOSED CHANGES Duke Energy proposes to modify the ONS TSs by removing extraneous information associated with RPS/ESPS digital upgrade and LPSW RB WPS modification.
The TS information associated with those design changes will be modified to reflect implementation of the engineering changes (ECs) on all ONS units. The proposed changes to TSs associated with this LAR are as follows: For TS 3.3.1, Reactor Protective System (RPS) Instrumentation:
* Condition A -Change the Completion Time column from: "1 hour for Unit(s) with the RPS digital upgrade not complete OR 4 hours for Unit(s) with RPS digital upgrade complete" to: "4 hours"* SR 3.3.1.4 -Change the Surveillance and Frequency columns to simply specify "Not Applicable".
* SR 3.3.1.5 -Delete the Note in the Surveillance column.* SR 3.3.1.6 -Delete the Note in the Surveillance column.* Table 3.3.1-1 -Delete "SR 3.3.1.4" in the Surveillance Requirements column (11 locations).
Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 5 of 13* Table 3.3.1-1 -Delete "SR 3.3.1.5" in the Surveillance Requirements column for Function No. 6 (Reactor Building High Pressure).
For TS 3.3.3, Reactor Protective System (RPS) -Reactor Trip Component (RTC):* Condition A -Delete "AND A.2" (in its entirety) in the Required Action column and associated "1 hour" in the Completion Time column." Condition A -Change numbering of Required Actions "A. 1.1" and "A. 1.2" to "A. 1" and"A.2," respectively.
For TS 3.3.5, Engineered Safeguards Protective System (ESPS) Input Instrumentation:
* Condition A -Change the Completion Time column from: "1 hour for Unit(s) with the ESPS digital upgrade not complete OR 4 hours for Unit(s) with ESPS digital upgrade complete" to: "4 hours"* SR 3.3.5.2 -Revise the current Note in the Surveillance column from "Only applicable to Unit(s) with ESPS digital upgrade complete" to "Not applicable to Reactor Building Pressure -High High parameter."* SR 3.3.5.3 -Delete the Note in the Surveillance column and change the remaining action text in the Surveillance column to "Not Applicable".
Also, change the text in the Frequency column to "Not Applicable." For TS 3.3.7, Engineered Safeguards Protective System (ESPS) Automatic Actuation Output Logic Channels:* SR 3.3.7.1 -Delete the Note in the Surveillance column.For TS 3.3.27, Low Pressure Service Water (LPSW) Reactor Building (RB) Waterhammer Prevention Circuitry:
* LCO 3.3.27 -Delete the LCO Note.For TS 3.6.5, Reactor Building Spray and Cooling Systems:* SR 3.6.5.1 -Delete the Note in the Surveillance column." SR 3.6.5.5 -Delete the Note in the Surveillance column.For TS 3.7.7, Low Pressure Service Water (LPSW) System:* LCO 3.7.7 -In the third statement, delete "on Units where the LPSW RB Waterhammer modification is installed."
Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 6 of 13* Condition B -Delete "on Units with LPSW RB Waterhammer modification installed" in the Condition column.* Condition C -Change the word "and" in "Condition A and B" to the word "or."* SR 3.7.7.1 -Delete "for Units with LPSW RB Waterhammer modification installed" in the first sentence in the Surveillance column." SR 3.7.7.5 -Delete "on Units with LPSW RB Waterhammer modification installed" in the Surveillance column.* SR 3.7.7.6 -Delete "for Units with LPSW RB Waterhammer modification installed" in the Surveillance column.For TS 3.7.8, Emer-gency Condenser Circulating Water (ECCW) System:* LCO 3.7.8 -Delete the LCO Note.The above Technical Specification changes are depicted in Attachment 1 of this submittal.
4 TECHNICAL EVALUATION As stated in the Background section (Section 2 above), the ONS Technical Specifications contain specific requirements for ONS units with or without the digital RPS/ESPS upgrade complete; for ONS units with or without the LPSW RB WPS modification complete; and for ONS units with the Service Water upgrade modifications complete.
Since the RPS/ESPS digital upgrade is complete on all three ONS units, TSs 3.3.1, 3.3.3, 3.3.5, and 3.3.7 can be revised to remove qualifiers for Technical Specification requirements, such as, "For ONS unit(s) with the digital upgrade complete" or "For ONS unit(s) with the digital upgrade not complete" since neither qualifying statement is necessary.
Thus, any notes that specify"with the digital upgrade complete" should be deleted and any Technical Specification requirements and notes for analog equipment (i.e., with the digital upgrade not completed) should also be deleted. Only Technical Specification requirements for RPS/ESPS equipment with the digital upgrade completed should remain in the Technical Specifications.
For the Technical Specification text pertaining to the LPSW RB WPS modification, TSs 3.3.27, 3.6.5 and 3.7.7 are affected.
However, the LPSW RB WPS modification is now installed on all three ONS units. Therefore, any Technical Specification text pertaining to"on Units with LPSW RB Waterhammer modification installed" no longer applies and is considered obsolete information.
Thus, any notes that specify "on (or for) Units with the LPSW RB Waterhammer modification installed" should be deleted. Technical Specification requirements for the LPSW RB WPS now apply for all ONS units.For the Note pertaining to Technical Specification applicability based on completion of the Service Water upgrade modification, TS 3.7.8 is affected.
The Service Water upgrade modification has been completed for each ONS unit. Thus, TS 3.7.8 requirements apply to each ONS unit. The Service Water upgrade modification Note no longer applies and is considered obsolete information.
Deletion of the Note removes obsolete information from the Technical Specifications, thus preventing possible operator confusion with TS 3.7.8.
Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 7 of 13 Regarding the deletion of the Technical Specification Surveillance Requirements pertaining to the RPS RB High Pressure trip function and ESPS RB Pressure -High-High actuation parameter, the NRC's safety evaluation (SE) for the ONS RPS/ESPS Digital Upgrade license amendment (Ref. 2) states, in SE Sections 3.10.3.1 and 3.10.3.2, that the purpose of SR 3.3.1.5 for the RPS and SR 3.3.5.2 for the ESPS is to manually verify that the software set points for the various RPS trip functions and ESPS actuation parameters, respectively, are correct (i.e., not incorrectly set). However, the RPS's RB High Pressure trip function and the ESPS's RB Pressure -High High actuation parameter are actuated by pressure switches that provide contact status only and do not have software set points. As such, the SR has been deleted for the subject RPS function and ESPS parameter.
For the Condition C wording error in TS 3.7.7, Condition C states: "Required Action and associated Completion Time of Condition A and B not met." The word "and," between letters "A" and "B," should be the word "or." The ONS Operations Staff has been made aware of this TS non-conservative wording error and has been directed to assume Condition C entry is required if the Required Action or associated Completion Time of Condition A or B are not met. As worded, TS 3.7.7 Condition C requires both Required Action and associated Completion Time of Condition A and Condition B not to be met before Condition C applies. Condition A is associated with one required LPSW pump inoperable and has a specified Required Action Completion Time of 72 hours to return the inoperable pump to Operable status. Condition B is associated with the LPSW water hammer prevention system (WPS) inoperable and has a specified Required Action Completion Time of 7 days to return the inoperable LPSW WPS to Operable status. Due to the differences in specified Completion Times for these Actions, the existing Condition C could allow the LPSW pump inoperable from Condition A to be inoperable for 7 days if the LPSW WPS from Condition B became inoperable at the same time as the LPSW pump. This allowance contradicts Condition A Required Action Completion Times.In addition, Actions statement for Condition C.1 and C.2 in TS Bases 3.7.7 states: "If the LPSW pump or WPS cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply..." The TS Bases clearly specifies that if either a required LPSW pump or the WPS cannot be restored to operable status with the required Completion Time, then Condition C is entered.By requiring Condition C entry when either a required LPSW pump or the WPS is inoperable beyond the required Completion Times of Condition A or Condition B, as applicable, TS 3.7.7 becomes more stringent than what Condition C currently requires.
Thus, the correction of the wording error in Condition C also renders TS 3.7.7 a more stringent TS.There is no impact on Updated Final Safety Analysis Report (UFSAR) accident analysis by implementing this proposed TS change.In summary, changing the second word "and" to "or" in Condition C corrects an apparent error and renders TS 3.7.7 a more stringent TS, and thus, an acceptable TS change.5 REGULATORY EVALUATION

===5.1 APPLICABLE===

REGULATORY REQUIREMENTS/CRITERIA The Oconee Nuclear Station (ONS) Technical Specification changes proposed in this license amendment request involve:* The removal of obsolete information that pertains to the Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade modification; Enclosure 
-Evaluation of Proposed Changes License Amendment Reauest No. 2013-05 Page 8 of 13* The removal of obsolete information that pertains to the Low Pressure Service Water (LPSW) Reactor Building (RB) Waterhammer Prevention System (WPS)modification;
* The removal of an obsolete Note that pertains to Technical Specification requirement applicability for the Emergency Condenser Circulating Water (ECCW) System;* The removal of Surveillance Requirement (SR) 3.3.1.5 applicability for the Reactor Protective System (RPS) RB High Pressure trip function since this RPS function has no software set point that can be verified;* The removal of SR 3.3.5.2 applicability for the Engineered Safeguards Protective System (ESPS) RB Pressure -High High actuation parameter since this ESPS function has no software set point that can be verified; and* Correction of the Condition C statement for the LPSW System Technical Specifications.
Due to the nature of these Technical Specification changes, the regulatory requirements/criteria that apply to this license amendment request are as follows: 10 CFR 50.36 -"Technical Specifications" Regulation 10 CFR 50.36 requires licensees have a Technical Specification limiting condition for operation (LCO) for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. When an LCO is not met, a licensee shall shut down the reactor or follow any remedial action permitted by the Technical Specifications until the condition can be met. Accompanying LCO and remedial actions are surveillance requirements (SRs) relating to test, calibration, or inspection to ensure the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.The LCOs and SRs that apply to the required digital RPS/ESPS equipment are still provided in revised Technical Specifications 3.3.1, 3.3.3, 3.3.5 and 3.3.7. The LCOs and SRs that apply to the LPSW RB WPS are still provided in revised Technical Specifications 3.3.27, 3.6.5 and 3.7.7. The LCOs and SRs that apply to the LPSW System are still provided in revised Technical Specifications 3.7.7. The LCOs and SRs that apply to the ECCW System are still provided in revised Technical Specification 3.7.8.10 CFR 50.59 -"Changes, tests and experiments" 10 CFR 50.90 -Application for amendment of license or construction permit" Regulation 10 CFR 50.59(c)(1)(i) requires licensees to submit a license amendment pursuant to 10 CFR 50.90 if a change to their Technical Specifications is required.Furthermore, the requirements of 10 CFR 50.59 necessitate that the NRC approve the Technical Specification changes before the Technical Specification changes are implemented.
This license amendment request meets the requirements of 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90.
Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 9 of 13 5.2 PRECEDENT License Amendments 358, 360, and 359 to ONS Units 1, 2, and 3 (Ref. 11), respectively, removed obsolete requirements from Technical Specifications after a modification was completed on all three ONS units. The proposed changes described in this license amendment request that remove obsolete requirements/notes from TS 3.3.1, 3.3.3, 3.3.5, 3.3.7, 3.3.27, 3.6.5, 3.7.7, and 3.7.8 are similar in nature.5.3 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Duke Energy Carolinas, LLC (Duke Energy), has evaluated the proposed change to the Oconee Nuclear Station (ONS) Technical Specifications (TSs) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
An analysis of the issue of no significant hazards consideration is presented as follows: Description of Amendment Request The proposed amendment would remove obsolete information from:* TS 3.3.1, "Reactor Protective System (RPS) Instrumentation;"* TS 3.3.3, "Reactor Protective System (RPS) -Reactor Trip Component (RTC);"" TS 3.3.5, "Engineered Safeguards Protective System (ESPS) Input Instrumentation;" and* TS 3.3.7, "Engineered Safeguards Protective System (ESPS) Automatic Actuation Output Logic Channels" associated with Technical Specification requirements for RPS/ESPS equipment that was replaced by the digital upgrade and are no longer needed due to completion of the digital upgrade on all three ONS units. Secondly, the proposed amendment would also remove obsolete information from:* TS 3.3.27, "Low Pressure Service Water (LPSW) Reactor Building (RB)Waterhammer Prevention Circuitry;"* TS 3.6.5, "Reactor Building Spray and Cooling Systems;" and* TS 3.7.7, "Low Pressure Service Water (LPSW) System" pertaining to LPSW RB Waterhammer Prevention System (WPS) modification due to completion of the WPS modification on all three units. Thirdly, the proposed amendment would remove an obsolete Note from TS 3.7.8, "Emergency Condenser Circulating Water (ECCW) System" pertaining to Technical Specification applicability based on completion of Service Water upgrade modifications.
The proposed amendment would also delete Surveillance Requirements (SRs) for software set point verification that are not applicable to the RPS RB High Pressure trip function and the ESPS RB Pressure -High High actuation parameter since the function/parameter consists of pressure switches which provide contact status to the system and have no software set points to verify.Lastly, the proposed amendment would correct a wording error in an Actions Condition statement for the LPSW System Technical Specifications.
Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 10 of 13 Basis for Proposed No Significant Hazards Consideration Determination As required by 10 CFR 50.91 (a), the Duke Energy analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented as follows: 1. Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?
Response:
No The proposed changes to Technical Specifications 3.3.1, 3.3.3, 3.3.5, 3.3.7, 3.3.27, 3.6.5, 3.7.7, and 3.7.8 do not modify the Reactor Protective System (RPS), Engineered Safeguards Protective System (ESPS), Low Pressure Service Water (LPSW) System, the LPSW Reactor Building (RB) Waterhammer Protection System (WPS) or the Emergency Condenser Circulating Water (ECCW) System, nor make any physical changes to the facility design, material, or construction standards.
The proposed changes remove obsolete information from the Technical Specifications that no longer apply to ONS; delete Surveillance Requirements (SRs) for the RPS RB High Pressure trip function and the ESPS RB Pressure -High High actuation parameter that are not applicable; and correct a wording error in a Condition statement for TS 3.7.7 which results in a more stringent Condition.
Since the removed information no longer applies to ONS, and the deleted SRs are for equipment features that do not exist for the RPS RB High Pressure trip function and the ESPS RB Pressure -High High actuation parameter, removal of the information and deletion of the SRs do not result in operation that will increase the probability of initiating an analyzed event.Likewise, the more restrictive requirement in the corrected Condition statement continues to ensure process variables, structures, systems, and components are maintained consistent with the safety analyses and licensing basis. The proposed Technical Specification changes do not alter assumptions relative to mitigation of an accident or transient event. The removal of the obsolete Technical Specification information, deletion of SRs for features that do not exist, and correction of the Technical Specification Condition statement have no effect on the process variables, structures, systems, and components that must be maintained consistent with the safety analyses and licensing basis. Therefore, the proposed Technical Specification changes do 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 changes to Technical Specifications 3.3.1, 3.3.3, 3.3.5, 3.3.7, 3.3.27, 3.6.5, 3.7.7, and 3.7.8 only remove obsolete information from the Technical Specifications pertaining to the RPS/ESPS digital upgrade, the LPSW RB WPS modification installation, and the ECCW System Service Water upgrade modification completion.
The proposed changes also delete SRs that verify features that do not exist for the RPS RB High Pressure trip function and the ESPS RB Pressure -High High actuation parameter.
Lastly, the proposed changes correct a wording error in a Condition statement for TS 3.7.7 which results in a more stringent Condition.
The changes do not alter the plant Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 11 of 13 configuration (no new or different type of equipment will be installed) or make changes in the methods governing normal plant operation.
The RPS, ESPS, LPSW System, LPSW RB WPS, and ECCW System are not associated with any design accident initiation; they only mitigate accidents.
However, these proposed Technical Specification changes are consistent with the assumptions in the safety analyses and licensing basis. Therefore, the proposed Technical Specification changes do not create the possibility of a new or different kind of accident from any kind of accident previously evaluated.
: 3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?Response:
No The proposed changes to Technical Specifications 3.3.1, 3.3.3, 3.3.5, 3.3.7, 3.3.27, 3.6.5, 3.7.7, and 3.7.8 remove information from the Technical Specifications pertaining to the RPS/ESPS digital upgrade, the LPSW RB WPS modification installation, and the ECCW System Service Water upgrade modification completion.
The proposed changes also delete SRs that verify features that do not exist for the RPS RB High Pressure trip function and the ESPS RB Pressure -High High actuation parameter.
Lastly, the proposed changes correct a wording error in a Condition statement for TS 3.7.7 which results in a more stringent Condition.
The removed Technical Specification information no longer applies to ONS operation and is considered obsolete; the deleted SRs cannot be performed since the affected plant equipment will not support SR testing by design; and the corrected TS 3.7.7 Condition statement results in a more conservative Technical Specification.
Removal of the Technical Specification obsolete information has no impact on the margin of safety since the equipment that the Technical Specification information applied to no longer exists at ONS. Deletion of SRs on the subject RPS/ESPS equipment has no impact on the margin of safety since the RPS/ESPS equipment, by design, will not support SR testing. Correction of the TS 3.7.7 Condition statement has no impact on the margin of safety since the correction results in a more conservative Technical Specification.
The changes maintain requirements within the safety analyses and licensing basis. As such, no question of safety is involved.Therefore, the proposed Technical Specification changes do not involve a significant reduction in a margin of safety.Based upon the above analysis, Duke Energy concludes that the requested changes do not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c),"Issuance of Amendment." 

==5.4 CONCLUSION==
S 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 Commission's 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.
Inclosure 
-Evaluation of Proposed Changes License Amendment Reauest No. 2013-05 Page 12 of 13 6 ENVIRONMENTAL CONSIDERATION Duke Energy Carolinas, LLC (Duke Energy) has evaluated this license amendment request against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. Duke Energy has determined that this license amendment request meets the criteria for a categorical exclusion as set forth in 10 CFR 51.22(c)(9).
This determination is based on the fact that the amendment meets the following specific criteria:* The amendment involves no significant hazard consideration as demonstrated in Section 5.* There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.* The principal barriers to the release of radioactive materials are not modified or affected by this change and no significant increases in the amounts of any effluent that could be released offsite will occur as a result of this change.* There is no significant increase in individual or cumulative occupational radiation exposure because the principal barriers to the release of radioactive materials are not modified or affected by this change.Therefore, no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment pursuant to 10 CFR 51.22(b).7 REFERENCES
: 1. Duke Energy Letter to NRC Document Control Desk, dated January 31, 2008, "License Amendment Request for Reactor Protective System/Engineered Safeguards Protective System Digital Upgrade, Technical Specification Change Number 2007-09" [ADAMS Accession No. ML080730339].
: 2. NRC Letter to Dave Baxter, ONS, dated January 28, 2010, "Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Acceptance of the Reactor Protective System and Engineered Safeguard Protective System (RPS/ESPS)
Digital Upgrade (TAC Nos. MD7999, MD8000, and MD8001)" [ADAMS Accession No.ML100220016].
: 3. Duke Energy Letter to NRC Document Control Desk, dated October 16, 2007, "License Amendment Request for Low Pressure Service Water Reactor Building Waterhammer Prevention System Modification to Mitigate Waterhammers Described in Generic Letter 96-06 and Associated Technical Specifications License Amendment Request (LAR) No.2006-05" [ADAMS Accession No. ML072920449].
: 4. NRC Letter to Dave Baxter, ONS, dated October 29, 2008, "Oconee Nuclear Station, Units 1, 2, and 3, Issuance Of Amendments Regarding Water Hammer Concerns (TAC Nos. MD7000, MD7001, and MD7002)" [ADAMS Accession No. ML082960070].
: 5. Duke Power Letter to NRC Document Control Desk, dated December 28, 1995,"Oconee Nuclear Station, Units 1, 2, and 3, Docket Nos. 50-269, -270, and -287, Summary of ECCW System Upgrade" [ADAMS Accession No. 9601020209].
: 6. Duke Power Letter to NRC Document Control Desk, dated August 28, 1997, "Oconee Nuclear Station Docket Nos. 50-269, -270, -287 Proposed Revision to Technical Enclosure 
-Evaluation of Proposed Changes License Amendment Request No. 2013-05 Page 13 of 13 Specifications for the Upgraded ECCW System Technical Specification Change# 96 -09" [ADAMS Accession No. 9709040405].
: 7. NRC Letter to William R. McCollum, ONS, dated April 24, 1998. "Issuance Of Amendments 
-Oconee Nuclear Station, Units 1, 2, and 3 (TAC Nos. M99487, M99488, And M99489)" [ADAMS Accession No. ML01 2040333].8. Duke Energy Letter to NRC Document Control Desk, dated October 16, 2007, "Oconee Nuclear Site, Units 1, 2, and 3, License Amendment Request for Low Pressure Service Water Reactor Building Waterhammer Prevention System Modification to Mitigate Waterhammers Described in Generic Letter 96-06 and Associated Technical Specifications, License Amendment Request (LAR) No. 2006-05" [ADAMS Accession No. ML072920449].
: 9. Duke Energy Letter to NRC Document Control Desk, dated October 23, 2008, "Oconee Nuclear Site, Units 1, 2, and 3, Request for Additional Information associated with License Amendment Request (LAR) for Low Pressure Service Water Reactor Building Waterhammer Prevention System Modification, LAR No. 2006-05" [ADAMS Accession No. ML083020409].
: 10. NRC Letter to Dave Baxter, ONS, dated October 29, 2008, "Oconee Nuclear Station, Units 1, 2 and 3, Issuance of Amendments Regarding Water Hammer Concerns (TAC Nos. MD7000, MD7001, and MD7002)" [ADAMS Accession No. ML082960070].
: 11. NRC Letter to Mr. Bruce H. Hamilton, ONS, dated December 11, 2007, "Oconee Nuclear Station, Units 1, 2, and 3, Issuance Of Amendments Regarding Removal Of Obsolete Technical Specification Requirements (TAC Nos. MD6734, MD6735, and MD6736) [ADAMS Accession No. ML0726301180].
License Amendment Request No. 2013-05 ATTACHMENT 1 Marked-Up Technical Specification Pages[15 pages following this cover page]NOTE: This attachment contains markups of existing TS pages (identified below) which incorporate the changes described in the Letter Enclosure.
3.3.1-1, -4, -5 and -6 3.3.3-1 3.3.5-1 and -3 3.3.7-2 3.3.27-1 3.6.5-4 and -5 3.7.7-1, -2 and -3 3.7.8-1 RPS Instrumentation 3.3.1 3.3 INSTRUMENTATION

====3.3.1 Reactor====
Protective System (RPS) Instrumentation LCO 3.3.1 APPLICABILITY:
ACTIONS Three channels of RPS instrumentation for each Function in Table 3.3. 1-1 shall be OPERABLE.According to Table 3.3.1-1.CONDITION REQUIRED ACTION COMPLETION TIME 4 I f -J I///A. One required channel inoperable.
A.1 Place channel in trip.qin How f- -mts with I/Mr- 8** O Wufle F r~1/4 hours for Wer- q--1. digital w4,-,-4 4 B. Two or more required channels inoperable.
OR Required Action and associated Completion Time of Condition A not met.B. 1 Enter the Condition referenced in Table 3.3.1-1 for the Function.Immediately A A (continued)
OCONEE UNITS 1, 2, & 3 3.3.1-1 Amendment Nos. N66, 366 & 8WI RPS Instrumentation Replace deleted text 3.3.1 with "Not Applicable" SURVEILLANCE SR 3.3.1.4 SIR 3.3.1.5 Manually verify the setpoints are correct.In accordance with the Surveillance Frequency Control Program SR 3.3.1.6 Manually actuate the output channel interposing relays.I In accordance with the Surveillance Frequency Control Program SR 3.3.1.7------------
NOTE --------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.3.1-4 Amendment Nos. I&M " "'"4', 1 RPS Instrumentation

====3.3.1 Table====
3.3.1-1 (page 1 of 2)Reactor Protective System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER FROM SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION B.1 REQUIREMENTS VALUE 1. Nuclear Overpower a. High Setpoint b. Low Setpoint 2. RCS High Outlet Temperature
: 3. RCS High Pressure 4. RCS Low Pressure 5. RCS Variable Low Pressure 6. Reactor Building High Pressure 1,2(a)2 (b) 3 (b)4 (b)'5 (b)1,2 1,2(a)1,2(a)1,2(a)1,2,3(c)C D C C C C C C C SR 3.3.1.1 SR 3.3.1.2 SQ64'a- 14-SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 OR SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SIR 3.3.1.3 SIR 3.3.1.5 SIR 3.3.1.5 SR 3.3.167< 105.5% RTP<5% RTP< 618OF< 2355 psig> 1800 psig As specified in the COLR:s 4 psig 7. Reactor Coolant Pump to Power>2% RTP with < 2 pumps operating 8. Nuclear Overpower Flux/Flow Imbalance 1,2(a)As specified in the COLR OCONEE UNITS 1, 2, & 3 3.3.1-5 RPS Instrumentation

====3.3.1 Table====
3.3.1-1 (page 2 of 2)Reactor Protective System Instrumentation APPLICABLE CONDITIONS ALLOWABLE MODES OR REFERENCED VALUE OTHER FROM SPECIFIED REQUIRED SURVEILLANCE FUNCTION CONDITIONS ACTION B.1 REQUIREMENTS
: 9. Main Turbine Trip (Hydraulic -a 30% RTP E S..444.4-&#xfd;.
800 psig Fluid Pressure)
SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 10. Loss of Main Feedwater Pumps _2% RTP F Sa&,,3,4d-
_> 75 psig (Hydraulic Oil Pressure)
SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 11. Shutdown Bypass RCS High 2 (b), 3 (b) D SR 3.3.1.1 :5 1720 psig Pressure S44-&44-4--
4 (b),5 (b) SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 (a) When not in shutdown bypass operation.
7 (b) During shutdown bypass operation with any CRD trip breakers in the closed position and the CRD System capable of rod withdrawal.(c) With any CRD trip breaker in the closed position and the CRD System capable of rod withdrawal.
OCONEE UNITS 1, 2, & 3 3.3.1-6 Amendment Nos. I 86, 3 & 36q j RPS -RTC~3.3 INSTRUMENTATION

====3.3.3 Reactor====
Protective System (RPS) -Reactor Trip Component (RTC)LCO 3.3.3 APPLICABILITY:
Four RTCs shall be OPERABLE.MODES 1 and 2, MODES 3, 4, and 5 with any control rod drive (CRD) trip breaker in the closed position and the CRD System capable of rod withdrawal.(continued)
OCONEE UNITS 1, 2, & 3 3.3.3-1 Amendment Nos.136&, 3,, & 376 ESPS Input Instrumentatio3.3 INSTRUMENTATION

====3.3.5 Engineered====

Safeguards Protective System (ESPS) Input Instrumentation 2 LCO 3.3.5 APPLICABILITY:
Three channels of ESPS input instrumentation for each Parameter in Table 3.3.5-1 shall be OPERABLE.According to Table 3.3.5-1.ACTIONS----------------------
NOTE Separate Condition entry is allowed for each ParamE--------------------------------------------------------
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Place channel in trip. 1- ,M f- F I.....Parameters with one [,., ,, ,,, c, , ,, ....channel inoperable.
4 hours f-- ' -" -" -B. One or more B.1 Be in MODE 3. 12 hours Parameters with two or more channels AND inoperable.
B.2.1 --------NOTE ------OR Only required for RCS Pressure -Low.Required Action and associated Completion Time not met. Reduce RCS pressure 36 hours< 1750 psig.AND (continued) 1//1 OCONEE UNITS 1, 2, & 3 3.3.5-1 Amendment Nos. 'W'3 & 367 ESPS Input Instrumentation

====3.3.5 SURVEILLANCE====

REQUIREMENTS (cor SR 3.3.5.2 Change NOTE to: "Not applicable to Reactor Building Pressure -High High parameter." Manually verify that the setpoints are correct.OCONEE UNITS 1, 2, & 3 3.3.5-3 Amendment Nos. .P, W.-4, &74 ESPS Automatic Actuation Output Logic Channels 3.3.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.7.1 -- XOZTE- ---OnI appli ble t Unit(s) with t ESP ital grad dcom e Manually actuate the output channel In accordance with the interposing relays. Surveillance Frequency Control Program SR 3.3.7.2 Perform automatic actuation output logic In accordance with the CHANNEL FUNCTIONAL TEST. Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.3.7-2 Amendment Nos.47-, &-;4,.
LPSW RB Waterhammer Prevention Circuitryl 3.3.270 3.3 INSTRUMENTATION 3.3.27 Low Pressure Service Water (LPSW) Reactor Building (RB) Waterhammer Prevention Circuitry z LCO 3.3.27 Three LPSW RB Waterhammer Prevention analog channels and two digital logic channels shall be OPERABLE.Ap pI ble each it afte omple i n of t LPS B W rha er difica n.on e.resp ive Un.APPLICABILITY:
MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required LPSW RB A.1 Restore required LPSW 7 days Waterhammer RB Waterhammer Prevention analog Prevention analog channel inoperable, channel to OPERABLE status.B. One required LPSW RB B.1 Restore required LPSW 7 days Waterhammer RB Waterhammer Prevention digital logic Prevention digital logic channel inoperable, channel to OPERABLE status.7 (continued)
OCONEE UNITS 1, 2, & 3 3.3.27-1 Amendment Nos. [,3, 64J 1 Reactor Building Spray and Cooling Systems 3.6.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 N N O --- ----Applc efor RB ooling s tern aft r the coetion of e LPSW B Wate aminme oificatio n the re ective Uit.Verify each reactor building spray and cooling manual and non-automatic power operated valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.In accordance with the Surveillance Frequency Control Program SR 3.6.5.2 Operate each required reactor building In accordance with the cooling train fan unit for _> 15 minutes. Surveillance Frequency Control Program SR 3.6.5.3 Verify each required reactor building spray In accordance with the pump's developed head at the flow test point Inservice Testing is greater than or equal to the required Program developed head.SR 3.6.5.4 Verify that the containment heat removal In accordance with the capability is sufficient to maintain post Surveillance Frequency accident conditions within design limits. Control Program (continuec OCONEE UNITS 1, 2, & 3 3.6.5-4 Amendment Nos.10.7-.2, 8.4, &gI]
Reactor Building Spray and Cooling Systems 3.6.5 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.5.5 c---------
N -s-----NO&#xfd;.pplic.ab for RB oling sy em aft the comp ion of th PSW Wate amme M ification the res ctive U t.Verify each automatic reactor building spray In accordance with the and cooling valve in each required flow path Surveillance Frequency that is not locked, sealed, or otherwise Control Program secured in position, actuates to the correct position on an actual or simulated actuation signal.SR 3.6.5.6 Verify each required reactor building spray In accordance with the pump starts automatically on an actual or Surveillance Frequency simulated actuation signal. Control Program SR 3.6.5.7 Verify each required reactor building cooling In accordance with the train starts automatically on an actual or Surveillance Frequency simulated actuation signal. Control Program SR 3.6.5.8 Verify each spray nozzle is unobstructed.
In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.6.5-5 Amendment Nos.{,8;2, .7,4, LPSW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Low Pressure Service Water (LPSW) System LCO 3.7.7 For Unit 1 or Unit 2, three LPSW pumps and one flow path shall be OPERABLE.For Unit 3, two LPSW pumps and one flow path shall be OPERABLE.The LPSW Waterhammer Prevention System (WPS) shall be r--------------------------
NOTE -----------------------
With either Unit 1 or Unit 2 defueled and appropriate LPSW loads secured on the defueled Unit, such that one LPSW pump is capable of mitigating the consequences of a design basis accident on the remaining Unit, only two LPSW pumps for Unit 1 or Unit 2 are required.APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required LPSW A.1 Restore required 72 hours pump inoperable.
LPSW pump to OPERABLE status.B. LPSW WPS ino erable B.1 Restore the LPSW 7 days on" Un.tc. "ith LP" WPS to OPERABLE 8 W ,, ,I status.L/C. Required Action and associated Completion Time of Condition A and B not met.Change "and" to "or" C. I Be in MODE 3.12 hours AND C.2 Be in MODE 5.60 hours J& I, Ir OCONEE UNITS 1, 2, & 3 3.7.7-1 Amendment Nos.1i., 9, & I LPSW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify LPSW leakage accumulator level is within In accordance with the Water levels between 20.5" to 41"-fe;- 61puts Wit Surveillance Frequency...W no .t.h....... 
........ ..h.... ......fit .......d. Control Program During LPSW testing, accumulator level > 41" is acceptable.
SR 3.7.7.2NOTE.........E-------------
Isolation of LPSW flow to individual components does not render the LPSW System inoperable.
Verify each LPSW manual, and non- In accordance with the automatic power operated valve in the flow Surveillance Frequency path servicing safety related equipment, that Control Program is not locked, sealed, or otherwise secured in position, is in the correct position.SR 3.7.7.3 Verify each LPSW automatic valve in the flow In accordance with the path that is not locked, sealed, or otherwise Surveillance Frequency secured in position, actuates to the correct Control Program position on an actual or simulated actuation signal.SR 3.7.7.4 Verify each LPSW pump starts automatically In accordance with the on an actual or simulated actuation signal. Surveillance Frequency Control Program SR 3.7.7.5 Verify LPSW leakage accumulator is able to In accordance with the provide makeup flow lost due to boundary Surveillance Frequency valve leakage on 'nitG With 6,PW Rf -Control Program Wa'terharngme ftzdeifie~tizr, irMt~lkd.I (continued)
OCONEE UNITS 1, 2, & 3 3.7.7-2 Amendment Nos. 7., 8.7.4, 9;.91 LPSW System 3.7.7 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.7.6 Verify LPSW WPS boundary valve leakage is In accordance with the-5 20 gpm for-...it 
.with. L..W R Surveillance Frequency"W^t.-hmmi_ ..Control Program K OCONEE UNITS 1, 2, & 3 3.7.7-3 Amendment Nos. 137-, 3;4, &-7.1 ECCW 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Emergency Condenser Circulating Water (ECCW) System LCO 3.7.8 Two ECCW siphon headers shall be OPERABLE.---- ----- ----- ----- --- TIE- --------- 
-------------- 
------NAappli ble o ach it unti after c mpletio o f t ecWt ipgrad modifi ations n the r secti e Unit.-APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required ECCW A.1 Restore required 72 hours siphon header ECCW siphon header inoperable, to OPERABLE status.B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Be in MODE 5. 60 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify required Essential Siphon Vacuum In accordance with the bi (ESV) pumps are in operation.
Surveillance Frequency Control Program (continued)
OCONEE UNITS 1, 2, & 3 3.7.8-1 Amendment Nos.[Xi., 8-4,4;7-)
I License Amendment Request No. 2013-05 ATTACHMENT 2 Retyped Technical Specification Pages[15 pages following this cover page]NOTE: Attached are clean, retyped TS pages (identified below) which incorporate the changes described in the Letter Enclosure 3.3.1-1, -4, -5 and -6 3.3.3-1 and -2 3.3.5-1 and -3 3.3.7-2 3.3.27-1 3.6.5-4 and -5 3.7.7-1 and -2 3.7.8-1 RPS Instrumentation 3.3.1 3.3 INSTRUMENTATION

====3.3.1 Reactor====
Protective System (RPS) Instrumentation LCO 3.3.1 Three channels of RPS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.APPLICABILITY:
According to Table 3.3.1-1.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required channel A.1 Place channel in trip. 4 hours inoperable.
B. Two or more required B.1 Enter the Condition Immediately channels inoperable, referenced in Table 3.3.1-1 for the OR Function.Required Action and associated Completion Time of Condition A not met.(continued)
OCONEE UNITS 1, 2, & 3 3.3.1-1 Amendment Nos. -, &
RPS Instrumentation

====3.3.1 SURVEILLANCE====

REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.1.4 Not Applicable Not Applicable SR 3.3.1.5 Manually verify the setpoints are correct. In accordance with the Surveillance Frequency Control Program SR 3.3.1.6 Manually actuate the output channel In accordance with the interposing relays. Surveillance Frequency Control Program SR 3.3.1.7 ---------NOTE--- ----Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.3.1-4 Amendment Nos.
RPS Instrumentation

====3.3.1 Table====
3.3.1-1 (page 1 of 2)Reactor Protective System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER FROM SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION B.1 REQUIREMENTS VALUE 1. Nuclear Overpower a. High Setpoint b. Low Setpoint 2. RCS High Outlet Temperature
: 3. RCS High Pressure 4. RCS Low Pressure 5. RCS Variable Low Pressure 6. Reactor Building High Pressure 7. Reactor Coolant Pump to Power 8. Nuclear Overpower Flux/Flow Imbalance 1,2(a)2 (b) 3 (b)4 (b), 5 (b)1,2 1,2(a)1,2(a)1,2(a)1,2,3(c)1,2(a)C D C C C C C C C SR 3.3.1.1 SR 3.3.1.2 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7 SR 3.3.1.1 SR 3.3.1.3 SR 3.3.1.5 SR 3.3.1.6 SR 3.3.1.7-< 105.5% RTP!g 5% RTP-< 6181F-< 2355 psig- 1800 psig As specified in the COLR< 4 psig>2% RTP with < 2 pumps operating As specified in the COLR 1,2(a)OCONEE UNITS 1, 2, & 3 3.3.1-5 Amendment Nos. -, &
RPS Instrumentation

====3.3.1 Table====
3.3.1-1 (page 2 of 2)Reactor Protective System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER FROM SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION B.1 REQUIREMENTS VALUE 9. Main Turbine Trip (Hydraulic
_ 30% RTP E SR 3.3.1.5 >800 psig Fluid Pressure)
SR 3.3.1.6 SR 3.3.1.7 10. Loss of Main Feedwater Pumps _ 2% RTP F SR 3.3.1.5 _ 75 psig (Hydraulic Oil Pressure)
SR 3.3.1.6 SR 3.3.1.7 11. Shutdown Bypass RCS High 2(b),3(b)
D SR 3.3.1.1 _< 1720 psig Pressure SR 3.3.1.5 4(b),5(b)
SR 3.3.1.6 SR 3.3.1.7 (a)(b)(c)When not in shutdown bypass operation.
During shutdown bypass operation with any CRD trip breakers in the closed position and the CRD System capable of rod withdrawal.
With any CRD trip breaker in the closed position and the CRD System capable of rod withdrawal.
OCONEE UNITS 1, 2, & 3 3.3.1-6 Amendment Nos. -, &
RPS- RTC 3.3.3 3.3 INSTRUMENTATION

====3.3.3 Reactor====
Protective System (RPS) -Reactor Trip Component (RTC)LCO 3.3.3 Four RTCs shall be OPERABLE.APPLICABILITY:
MODES 1 and 2, MODES 3, 4, and 5 with any control rod drive (CRD) trip breaker in the closed position and the CRD System capable of rod withdrawal.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RTC inoperable.
A.1 Trip the associated 1 hour CRD trip breaker.OR A.2 Remove power from 1 hour the associated CRD trip breaker.B. Two or more RTCs B. 1 Be in MODE 3. 12 hours inoperable in MODE 1, 2, or 3. AND OR B.2.1 Open all CRD trip 12 hours breakers.Required Action and associated Completion OR Time not met in MODE 1, 2, or 3. B.2.2 Remove power from all 12 hours CRD trip breakers.(continued)
OCONEE UNITS 1, 2, & 3 3.3.3-1 Amendment Nos. -, &
RPS -RTC 3.3.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. Two or more RTCs C.1 Open all CRD trip 6 hours inoperable in MODE 4 breakers.or 5.OR OR C.2 Remove powerfrom all 6 hours Required Action and CRD trip breakers.associated Completion Time not met in MODE 4 or 5.SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1,2, & 3 3.3.3-2 Amendment Nos.
ESPS Input Instrumentation 3.3.5 3.3 INSTRUMENTATION

====3.3.5 Engineered====

Safeguards Protective System (ESPS) Input Instrumentation LCO 3.3.5 Three channels of ESPS input instrumentation for each Parameter in Table 3.3.5-1 shall be OPERABLE.APPLICABILITY:
According to Table 3.3.5-1.ACTIONS------------
NOT r --------------------------------------------------------
Separate Condition entry is allowed for each Parameter.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Place channel in trip. 4 hours Parameters with one channel inoperable.
B. One or more B.1 Be in MODE 3. 12 hours Parameters with two or more channels AND inoperable.
B.2.1 --------NOTE--- --OR Only required for RCS Pressure -Low.Required Action and -----------
associated Completion Time not met. Reduce RCS pressure 36 hours< 1750 psig.AND (continued)
OCONEE UNITS 1, 2, & 3 3.3.5-1 Amendment Nos. -, &
ESPS Input Instrumentation

====3.3.5 SURVEILLANCE====

REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.3.5.2 ----------------
NOTE ------------------------------
Not applicable to Reactor Building Pressure -High High parameter.
Manually verify that the setpoints are correct. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3 Not Applicable Not Applicable SR 3.3.5.4 Perform CHANNEL CALIBRATION.
In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.3.5-3 Amendment Nos. -, -,
ESPS Automatic Actuation Output Logic Channels 3.3.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.7.1 Manually actuate the output channel In accordance with the interposing relays. Surveillance Frequency Control Program SR 3.3.7.2 Perform automatic actuation output logic In accordance with the CHANNEL FUNCTIONAL TEST. Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.3.7-2 Amendment Nos. -, -,
LPSW RB Waterhammer Prevention Circuitry 3.3.27 3.3 INSTRUMENTATION 3.3.27 Low Pressure Service Water (LPSW) Reactor Building (RB) Waterhammer Prevention Circuitry LCO 3.3127 Three LPSW RB Waterhammer Prevention analog channels and two digital logic channels shall be OPERABLE.APPLICABILITY:
MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required LPSW RB A.1 Restore required LPSW 7 days Waterhammer RB Waterhammer Prevention analog Prevention analog channel inoperable, channel to OPERABLE status.B. One required LPSW RB B.1 Restore required LPSW 7 days Waterhammer RB Waterhammer Prevention digital logic Prevention digital logic channel inoperable, channel to OPERABLE status.(continued)
OCONEE UNITS 1, 2, & 3 3.3.27-1 Amendment Nos. -, -, & I Reactor Building Spray and Cooling Systems 3.6.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify each reactor building spray and cooling In accordance with the manual and non-automatic power operated Surveillance Frequency valve in the flow path that is not locked, Control Program sealed, or otherwise secured in position is in the correct position.SR 3.6.5.2 Operate each required reactor building In accordance with the cooling train fan unit for _> 15 minutes. Surveillance Frequency Control Program SR 3.6.5.3 Verify each required reactor building spray In accordance with the pump's developed head at the flow test point Inservice Testing is greater than or equal to the required Program developed head.SR 3.6.5.4 Verify that the containment heat removal In accordance with the capability is sufficient to maintain post Surveillance Frequency accident conditions within design limits. Control Program (continued)
OCONEE UNITS 1, 2, & 3 3.6.5-4 Amendment Nos.
Reactor Building Spray and Cooling Systems 3.6.5 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.5.5 Verify each automatic reactor building spray In accordance with the and cooling valve in each required flow path Surveillance Frequency that is not locked, sealed, or otherwise Control Program secured in position, actuates to the correct position on an actual or simulated actuation signal.SR 3.6.5.6 Verify each required reactor building spray In accordance with the pump starts automatically on an actual or Surveillance Frequency simulated actuation signal. Control Program SR 3.6.5.7 Verify each required reactor building cooling In accordance with the train starts automatically on an actual or Surveillance Frequency simulated actuation signal. Control Program SR 3.6.5.8 Verify each spray nozzle is unobstructed.
In accordance with the Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.6.5-5 Amendment Nos. -, -, I LPSW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Low Pressure Service Water (LPSW) System LCO 3.7.7 For Unit 1 or Unit 2, three LPSW pumps and one flow path shall be OPERABLE.For Unit 3, two LPSW pumps and one flow path shall be OPERABLE.The LPSW Waterhammer Prevention System (WPS) shall be OPERABLE.
I------------------------
NOTE -----------------------
With either Unit 1 or Unit 2 defueled and appropriate LPSW loads secured on the defueled Unit, such that one LPSW pump is capable of mitigating the consequences of a design basis accident on the remaining Unit, only two LPSW pumps for Unit 1 or Unit 2 are required.--------------------------------------------------------------------------------------------------
APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required LPSW A.1 Restore required 72 hours pump inoperable.
LPSW pump to OPERABLE status.B. LPSW WPS B.1 Restore the LPSW 7 days inoperable.
WPS to OPERABLE status.C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time of Condition A or AND B not met.C.2 Be in MODE 5. 60 hours OCONEE UNITS 1, 2, & 3 3.7.7-1 Amendment Nos. _, _, &
LPSW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify LPSW leakage accumulator level is within In accordance with the Water levels between 20.5" to 41". During LPSW Surveillance Frequency testing, accumulator level > 41" is acceptable.
Control Program SR 3.7.7.2 ------------
NOTE -------------
Isolation of LPSW flow to individual components does not render the LPSW System inoperable.
Verify each LPSW manual, and non- In accordance with the automatic power operated valve in the flow Surveillance Frequency path servicing safety related equipment, that Control Program is not locked, sealed, or otherwise secured in position, is in the correct position.SR 3.7.7.3 Verify each LPSW automatic valve in the flow In accordance with the path that is not locked, sealed, or otherwise Surveillance Frequency secured in position, actuates to the correct Control Program position on an actual or simulated actuation signal.SR 3.7.7.4 Verify each LPSW pump starts automatically In accordance with the on an actual or simulated actuation signal. Surveillance Frequency Control Program SR 3.7.7.5 Verify LPSW leakage accumulator is able to In accordance with the provide makeup flow lost due to boundary Surveillance Frequency valve leakage. Control Program SR 3.7.7.6 Verify LPSW WPS boundary valve leakage is In accordance with the< 20 gpm. Surveillance Frequency Control Program OCONEE UNITS 1, 2, & 3 3.7.7-2 Amendment Nos. -, -, &
ECCW 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Emergency Condenser Circulating Water (ECCW) System LCO 3.7.8 Two ECCW siphon headers shall be OPERABLE.APPLICABILITY:
MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required ECCW A.1 Restore required 72 hours siphon header ECCW siphon header inoperable, to OPERABLE status.B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Be in MODE 5. 60 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify required Essential Siphon Vacuum In accordance with the (ESV) pumps are in operation.
Surveillance Frequency Control Program (continued)
OCONEE UNITS 1, 2, & 3 3.7.8-1 Amendment Nos. -, -, I}}