ML14269A078

Oconee, Units 1, 2, and 3, License Amendment Request for Adoption of Technical Specification Task Force (TSTF) - 513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation; License Amendment Request No.

ML14269A078
Person / Time
Site:	Oconee
Issue date:	09/18/2014
From:	Batson S L Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2014-105
Download: ML14269A078 (37)

Text

Scott L. BatonVice President ENERGY, Oconee Nuclear StationDuke EnergyONO1VP 1 7800 Rochester HwySeneca, SC 29672o: 864.873.3274 ONS-2014-105

f. 864.873.4208 Scott.Batson@duke-energy.com September 18, 2014 10 CFR 50.90ATTN: Document Control DeskU.S. Nuclear Regulatory Commission 11555 Rockville PikeRockville, MD 20852Duke Energy Carolinas, LLC (Duke Energy)Oconee Nuclear Station, Units 1, 2, and 3Docket Nos. 50-269, 50-270, 50-287

Subject:

License Amendment Request for Adoption of Technical Specification Task Force(TSTF) -513, Revision 3, "Revise PWR Operability Requirements and Actions ForRCS Leakage Instrumentation;"

License Amendment Request No. 2011-03In accordance with the provisions of Section 50.90 of Title 10 of the Code of FederalRegulations (10 CFR), Duke Energy is submitting a request for an amendment to the Technical Specifications (TSs) for Oconee Nuclear Station (ONS), Units 1, 2, and 3.The proposed amendment would revise the ONS Technical Specifications to define a new timelimit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or morerequired monitors are inoperable; and make Technical Specification Bases changes whichreflect the proposed changes and more accurately reflect the contents of the facility designbasis related to operability of the RCS leakage detection instrumentation.

These changes areconsistent with NRC-approved Revision 3 to TSTF Improved Standard Technical Specification (STS) Change Traveler TSTF-513, "Revise PWR [Pressurized Water Reactor]

Operability Requirements and Actions for RCS Leakage Instrumentation."

The availability of this TSimprovement was announced in the Federal Register (76 FR 189) on January 3, 2011, as partof the consolidated line item improvement process (CLIIP).For ONS Units 1, 2, and 3, adherence to TSTF-513 TS improvements will require the addition ofcontainment atmosphere gaseous radioactivity monitor requirements to TS 3.4.15, "RCSLeakage Detection Instrumentation."

Thus, the proposed amendment also incorporates the newrequirements for a containment atmosphere gaseous radioactivity monitor into the Technical Specifications.

Included with this cover letter are as follows:* Letter Enclosure

-Evaluation of the Proposed Changes.* Attachment 1 -Marked-Up Pages of Existing TSs to Show Proposed Changes.* Attachment 2 -Marked-Up Pages of Existing TS Bases to Show Proposed Changes.C ol U.S. Nuclear Regulatory Commission

' September 18, 2014Page 2* Attachment 3 -Retyped (clean) TS pages." Attachment 4 -Retyped (clean) TS Bases pages.Duke Energy requests approval of the proposed LAR by September 18, 2015, with a 120 dayimplementation period.In accordance with 10 CFR 50.91 (a)(1), "Notice for Public Comment,"

the analysis about theissue of no significant hazards consideration using the standards in 10 CFR 50.92 is beingprovided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.Also, in accordance with 10 CFR 50.91(b)(1),

"State Consultation,"

a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to theSouth Carolina Department of Health & Environmental Control.

There are no new regulatory commitments contained in this correspondence.

If there are any questions regarding the content of this document or if additional information isneeded, please contact Stephen C. Newman, Lead Engineer

-Regulatory Affairs Group,Oconee Nuclear Station, at (864) 873-4388.

I declare under penalty of perjury that the foregoing is correct and true. Executed on this 1 8thday of September 2014.Sincerely, Scott L. BatsonSite Vice President Oconee Nuclear Station

Enclosure:

Evaluation of the Proposed Changes.Attachments:

1. Technical Specification Page Marked-Ups

2. Technical Specification Bases Page Marked-Ups

3. Retyped Technical Specification Pages4. Retyped Technical Specification Bases Pages 1.S. Nuclear Regulatory Commission

• ", _September 18, 2014Page 3xc w/enclosure/attachments:

Mr. Victor McCreeAdministrator, Region IIU.S. Nuclear Regulatory Commission Marquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257 Mr. James R. Hall, Senior Project Manager(by electronic mail only)Office of Nuclear Reactor Regulation, Mailstop:

O-8G9AU. S. Nuclear Regulatory Commission 11555 Rockville PikeRockville, MD 20852Mr. Eddy CroweNRC Senior Resident Inspector Oconee Nuclear StationSusan E. Jenkins,

Manager, Infectious and Radioactive Waste Management Division of Waste Management South Carolina Department of Health & Environmental Control2600 Bull Street,Columbia, SC 29201 ENCLOSURE EVALUATION OF THE PROPOSED CHANGESLICENSE AMENDMENT REQUEST NO. 2011-03

Subject:

Proposed License Amendment Request for the Adoption of TSTF-513, Revision 3, "Revise PWR Operability Requirements and Actions for RCSLeakage Instrumentation" 1 DESCRIPTION 2 PROPOSED CHANGES3 BACKGROUND 4 TECHNICAL ANALYSIS5 REGULATORY SAFETY ANALYSIS6 ENVIRONMENTAL CONSIDERATION 7 REFERENCES Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Page 1 of 9I DESCRIPTION The proposed amendment would revise the Technical Specifications (TSs) to define a newtime limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakagewhen one or more required monitors are inoperable; and make conforming TS Baseschanges.

These changes are consistent with NRC-approved Revision 3 to Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change TravelerTSTF-513, "Revise PWR Operability Requirements and Actions for RCS LeakageInstrumentation."

The availability of this TS improvement was announced in the FederalRegister on January 3, 2011 (76 FR 189) as part of the consolidated line item improvement process (CLIIP).For Duke Energy Carolinas',

LLC (Duke Energy) Oconee Nuclear Station, Units 1, 2, and 3(hereafter referred to as "ONS"), adherence to TSTF-513, Revision 3 (hereafter referred toas "TSTF-513")

TS improvements will require the addition of containment atmosphere gaseous radioactivity monitor requirements to TS 3.4.15, "RCS Leakage Detection Instrumentation."

TS 3.4.15 requirements for a containment atmosphere gaseousradioactivity monitor were previously in the ONS Technical Specifications, but wereremoved, as described on the next page. Thus, the proposed changes described in thislicense amendment request also incorporate the new requirements for a containment atmosphere gaseous radioactivity monitor into the ONS Technical Specifications.

Thisadditional scope will bring ONS closer in-line with the STS for Babcock and Wilcox reactorplants (NUREG-1430) regarding RCS leakage detection instrumentation requirements.

2 PROPOSED CHANGESThe proposed changes that implement TSTF-513 revise and add a new Condition C to TS3.4,15, "RCS Leakage Detection Instrumentation,"

and revise the associated bases. NewCondition C is applicable when the containment atmosphere gaseous radioactivity monitor isthe only operable TS-required monitor (i.e., all other monitors are inoperable).

NewCondition C Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restoring another monitor within 7 days. Additionally, theTS Bases are revised to clarify the specified safety function for each required instrument inthe limiting condition for operation (LCO) Bases, delete discussion from the Bases that couldbe construed to alter the meaning of TS operability requirements, and reflect the changesmade to TS 3.4.15.The proposed TSTF-513 changes also correct inappropriate references to "required" equipment in TS 3.4.15. In two locations the specifications incorrectly refer to "required" containment sump level indication.

The term "required" is reserved for situations in whichthere are multiple ways to meet the LCO, such as a requirement for either a gaseous orparticulate radioactivity monitor.

The incorrect use of the term "required" is removed fromTS 3.4.15 Condition A.Duke Energy is proposing variations from the TS changes described in TSTF-513 and fromthe NRC staffs model safety evaluation (SE) referred to in the Federal Register Noticepublished on January 3, 2011 (76 FR 189) as part of the CLIIP Notice of Availability.

Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Pa-qe 2 of 9The variations are necessary since:A. ONS TS 3.4.15 does not currently contain requirements for a containment atmosphere gaseous radioactivity monitor.The TS 3.4.15 LCO requirements for a containment atmosphere gaseous radioactivity monitor were previously in the ONS Technical Specifications, but were removed in 2007(as approved in NRC letter dated December 19, 2007 [Reference 1]). However, thecontainment atmosphere gaseous radioactivity monitor removed from the Technical Specifications (i.e., RIA-49) remained in-service for operational use and continued to bemaintained via the Maintenance Rule. In order for TSTF-513 to apply to ONS, therequirements for a containment atmosphere gaseous radioactivity monitor must beadded to current TS 3.4.15. Thus, this license amendment request also includes TSchanges to add requirements for a containment atmosphere gaseous radioactivity

monitor, resulting in ONS TS 3.4.15 closer alignment to NUREG-1430.

Theseadditional TS changes are as follows:" LCO 3.4.15.b is changed to state "One containment atmosphere radioactivity monitor (gaseous or particulate)."

" Bases Background section discussion of containment atmosphere radioactivity detection system for monitoring particulate activity is revised to includemonitoring for gaseous activity also." Bases LCO section discussion of acceptable instruments for providing a meansof diverse measurement is revised to include the containment atmosphere gaseous radioactivity monitor." Bases Actions B. 1.1, B. 1.2, and B.2 discussion of inoperable containment atmosphere radioactivity monitoring instrumentation is revised to include thecontainment atmosphere gaseous radioactivity monitor.B. The required Completion Time allowed for Required Action C.1 in ONS TS 3.4.15 differsfrom the required Completion Time for the same Required Action specified in TSTF-513.

The required Completion Time allowed for Required Action C.1 in ONS TS 3.4.15 (i.e.,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) is the standard, maximum time span specified throughout the ONS TS (i.e.,TS applicable in MODES 1 and 2) for the action of placing a unit in MODE 3.NUREG-1430, Revision 3.0, upon which TSTF-513 is based, specifies a maximum timespan of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place a unit in MODE 3. However, TSTF-513 changes only re-letter the associated Required Action from "C. 1" to "D. 1" without changing the requiredCompletion Time; and thus, the NRC model SE does not address the requiredCompletion Time. ONS will maintain the 12-hour Completion Time for TS 3.4.15 toremain consistent with the remainder of the ONS Technical Specifications.

This requiredCompletion Time difference has no effect on the NRC model SE.C. The Bases for ONS TS 3.4.15 has some differences from the (NUREG-1430, Revision3.0) TS Bases marked-up in TSTF-513.

One of the main differences is that the TS Bases marked-up in TSTF-513 references twoNRC documents, General Design Criterion (GDC) 30 of Appendix A to 10 CFR 50,issued on February 20, 1971 (as part of Federal Register Notice 36 FR 3256), andRegulatory Guide (RG) 1.45, issued in May, 1973, which provide regulatory requirements and guidance, respectively, for detecting RCS leakage.

However, ONSwas designed in the late 1960s, which pre-dated these two NRC documents.

Thus,these documents were not in the original licensing basis for ONS, and therefore, notdiscussed in ONS TS Bases B 3.4.15. Instead, the ONS Bases specify that ONS

,nclosure

-Evaluation of Proposed ChangesLicense Amendment Reauest No. 2011-03 Page 3 of 9Design Criteria require means for detecting RCS leakage.

Such design criteria arediscussed in ONS Updated Final Safety Analysis Report (UFSAR) Section 3.1.A second difference between the ONS TS Bases and the TSTF-513 Bases is the lack ofdiscussion in the Background section of the ONS TS Bases B 3.4.15 involving sumpalarm features and containment humidity levels. The ONS Bases do not have suchdiscussions since the subject parameters are not monitored for RCS leakage detection at ONS (Reference 2). However, since the NRC model SE does not discuss sumpalarm features and only mentions "humidity" in quoted text from RG 1.45, Revision 0,this difference has no effect on the NRC model SE.Other differences between the ONS TS Bases B 3.4.15 and the TSTF-513 Bases areminor in nature and ONS-specific (i.e., use of the term "unit" instead of "plant" and "levelindication" instead of "monitor").

Therefore, such differences are justified and will remainin ONS TS Bases B 3.4.15. These differences have no effect on the NRC model SE.D. Duke Energy also intends to add a clarification phrase in the ONS TS Bases B 3.4.15 toensure plant operators correctly interpret re-lettered Action Condition E. The Basesdiscussion for re-lettered Action Condition E will be modified by the addition of thephrase "(normal sump level indication and containment atmosphere radioactivity monitor)"

directly following the word "instruments" in the first line of text. This addedclarification phrase has no effect on the NRC model SE.Based on the above discussions of Duke Energy's proposed variations from the TS changesdescribed in TSTF-513, the NRC model SE for TSTF-513 implementation is affected by, andrequires modification for, the following variations:

• Addition of a containment atmosphere gaseous radioactivity monitor to LCO 3.4.15.b.

• Addition of discussion of containment atmosphere gaseous radioactivity monitoring inthe Bases Background, LCO and Actions sections.

• The extent that ONS complies with GDC 30 and RG 1.45.Even though Duke Energy is proposing variations to TSTF-513 implementation for ONS, it isDuke Energy's intent to adhere to the TS changes described in TSTF-513 as close asmaterially possible.

Markups showing the proposed changes to the TS pages and TS Bases pages affected bythe proposed changes are provided in Attachments 1 and 2, respectively.

Retyped (clean)TS pages and TS Bases pages are provided in Attachments 3 and 4, respectively.

3 BACKGROUND NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity,"

dated August 3, 2005, informed addressees that the reactor coolant activity assumptions forprimary containment atmosphere gaseous radioactivity monitors may be non-conservative.

This means the monitors may not be able to detect a one gallon per minute leak within onehour. Some licensees have taken action in response to IN 2005-24 to remove the gaseousradioactivity monitor from the Technical Specification list of required monitors.

Duke Energyperformed this action for ONS in 2007 (Reference 1). However, industry experience hasshown that the primary containment atmosphere gaseous radioactivity monitor is often thefirst monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRCstaff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to Enclosure

-Evaluation of Proposed ChangesLicense Amendment Reauest No. 2011-03 Paae 4 of 9address the issue identified in IN 2005-24.

The agreed solution is to retain the primarycontainment atmosphere gaseous radioactivity monitor in the LCO list of requiredequipment, revise the specified safety function of the gas monitor to specify the requiredinstrument sensitivity level, revise the Actions to require additional monitoring, and provideless time before a plant shutdown is, required when the primary containment atmosphere gaseous radioactivity monitor is the only operable monitor.

Therefore, Duke Energy isrequesting in this license amendment request to add requirements for the containment atmosphere gaseous radioactivity monitor back into TS 3.4.15 and to implement the TSchanges specified in TSTF-513 as they apply to ONS.4 TECHNICAL ANALYSISDuke Energy has reviewed TSTF-513, Revision 3, and the model SE published onJanuary 3, 2011 (76 FR 189) as part of the CLIIP Notice of Availability.

Duke Energy hasconcluded that, with the addition of requirements for a containment atmosphere gaseousradioactivity monitor back into TS 3.4.15, the technical bases presented in TSTF Traveler-513, Revision 3, and the model SE prepared by the NRC staff (modified to incorporated the DukeEnergy proposed variations listed near the end of Section 2) are applicable to ONS.The proposed amendment revises TS LCO 3.4.15.b to allow either a containment atmosphere gaseous radioactivity monitor or a containment atmosphere particulate radioactivity monitor to be a means of detecting RCS leakage.

Although the proposed TSLCO will be less restrictive than the current TS LCO, it more closely conforms to the NRC-approved Standard Technical Specifications for Babcock and Wilcox reactor plants(NUREG-1430).

The proposed amendment revises the TS Bases to include the addition ofa containment atmosphere gaseous radioactivity monitor into TS 3.4.15 and revises thelanguage in the TS Bases that describes when the gaseous and particulate containment atmosphere radioactivity monitors are operable.

The proposed amendment requiresadditional batch or manual RCS leakage monitoring to be performed when the addedprimary containment atmosphere gaseous radioactivity monitor is the only operablecontinuous or automatic monitor.

These alternative batch methods provide an RCS leakagedetection capability similar to the TS-required methods.

The grab sample has an RCSleakage detection capability that is comparable to that of the containment particulate radioactivity monitor.

The proposed Actions and Completion Times for grab samples areadequate because use of frequent grab samples provides additional assurance (in additionto the mass balances required by Conditions A and B) that any significant RCS leakage willbe detected prior to significant reactor coolant pressure boundary (RCPB) degradation.

The plant licensing basis for ONS relative to conformance with NRC design criteria isdiscussed in UFSAR Section 3.1, "Conformance with NRC General Design Criteria."

TheONS Units 1, 2, and 3 construction permits (all issued on November 6, 1967) preceded theissuance of approved GDC (issued on February 20, 1971) specified in 10 CFR 50 AppendixA. Thus, the principal design criteria for ONS were developed in consideration of theseventy (70) proposed General Design Criteria for Nuclear Power Plant Construction Permits issued by the Atomic Energy Commission (AEC) in a proposed rule-making published for 10 CFR 50 in the Federal Register on July 11, 1967. UFSAR Section 3.1.16specifies that the RCS leakage detection instrumentation for ONS was designed to meet1967-proposed GDC 16, "Monitoring Reactor Coolant Pressure Boundary,"

which simplystates "Means shall be provided for monitoring the reactor coolant pressure boundary todetect leakage."

Therefore, 1971-approved GDC 30, "Quality of reactor coolant pressure Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Page 5 of 9boundary,"

is not part of the ONS licensing basis. However, ONS does meet the intent ofthe portion of GDC 30 which specifies a means shall be provided for detecting reactorcoolant leakage.5 REGULATORY SAFETY ANALYSIS5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Duke Energy Carolina, LLC (Duke Energy),

has evaluated the proposed changes to theOconee Nuclear Station (ONS) Technical Specifications (TSs) using the criteria in10 CFR 50.92 and has determined that the proposed changes do not involve asignificant hazards consideration.

An analysis of the issue of no significant hazardsconsideration is presented below:Description of Amendment Request:

The proposed amendment would revise TS 3.4.15,"RCS Leakage Detection Instrumentation" Limiting Conditions for Operation, Conditions and Required Actions and add the licensing basis for the gaseous radioactivity monitor,as well as make associated changes to TS Bases B 3.4.15.Basis for proposed no significant hazards consideration determination:

As required by10 CFR 50.91(a),

the Duke Energy analysis of the issue of no significant hazardsconsideration using the standards in 10 CFR 50.92 is presented below:1. Does the Proposed Change Involve a Significant Increase in the Probability orConsequences of an Accident Previously Evaluated?

Response:

NoThe proposed change modifies the operability requirements for the ReactorCoolant System (RCS) leakage detection instrumentation to include acontainment atmosphere gaseous radioactivity monitor and incorporates areduction in the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radioactivity monitor.

Accidents described in the ONSUpdated Final Safety Analysis Report involving RCS leakage are both small andlarge breaks in reactor coolant pressure boundary (RCPB) piping. Suchaccidents already assume RCPB leakage (i.e., gross leakage).

Thus, anychange to Technical Specifications involving equipment that monitor RCPBleakage is not a precursor to any accident previously evaluated.

In addition, anychange to Technical Specifications involving equipment that monitor RCPBleakage is not used to mitigate the consequences of any accident previously evaluated.

Therefore, it is concluded that the proposed change does not involvea significant increase in the probability or consequences of an accidentpreviously evaluated.

Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Page 6 of 92. Does the Proposed Change Create the Possibility of a New or Different Kind ofAccident from any Accident Previously Evaluated?

Response:

NoThe proposed change modifies the operability requirements for the RCS leakagedetection instrumentation to include a containment atmosphere gaseousradioactivity monitor and incorporates a reduction in the time allowed for the plantto operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radioactivity monitor.

The proposed change does not involve a physical alteration of the plant(no new or different type of equipment will be installed) or a change in themethods governing normal plant operation.

The proposed change maintains sufficient continuity and diversity of leak detection capability that the probability ofpiping evaluated and approved for Leak-Before-Break progressing to piperupture remains extremely low. Therefore, it is concluded that the proposedchange does not create the possibility of a new or different kind of accident fromany previously evaluated.

3. Does the Proposed Change Involve a Significant Reduction in a Margin ofSafety?Response:

NoThe proposed change modifies the operability requirements for the RCS leakagedetection instrumentation to include a containment atmosphere gaseousradioactivity monitor and incorporates a reduction in the time allowed for the plantto operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radioactivity monitor.

By adding the option of utilizing a containment atmosphere gaseousradioactivity monitor in place of the existing containment atmosphere particulate radioactivity

monitor, ONS more closely conforms to NUREG-1430, Revision 3.0TS limiting conditions for operation requirements for RCS leakage detection instrumentation.

Since NUREG-1430 is an NRC-controlled

document, thereduction in margin of safety for adding the option of utilizing a containment atmosphere gaseous radioactivity monitor in place of the existing containment atmosphere particulate radioactivity monitor is acceptable to the NRC and notconsidered significant.

The reduced amount of time the plant is allowed tooperate with only the containment atmosphere gaseous radioactivity monitoroperable increases the margin of safety by increasing the likelihood that anincrease in RCS leakage will be detected before it potentially results in grossfailure.

Therefore, it is concluded that the proposed change does not involve asignificant reduction in a margin of safety.Based upon the above analysis, Duke Energy concludes that the requested changedoes not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c),

"Issuance of Amendment."

Enclosure

-Evaluation of Proposed ChangesLicense Amendment Reauest No. 2011-03Paae 7 of 95.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability onJanuary 3, 2011 (76 FR 189). Duke Energy has reviewed the NRC staffs model SEreferenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is not applicable to ONS. The regulatory requirements that apply tothis LAR, and how ONS satisfies the requirements, are provided in the following table.Regulatory RequirementslC riteria How Satisfied 10 CFR 50.36 -The TS requirements shall LCOs and surveillance requirements forinclude the following categories:

RCS Leakage Detection Instrumentation (1) safety limits, limiting safety systems are still provided in revised TS 3.4.15.settings and control settings, (2) limiting conditions for operation (LCOs),(3) surveillance requirements, (4) design features, and(5) administrative controls.

10 CFR 50.59(c)(1)(i)

-a licensee is This LAR meets the requirements ofrequired to submit a license amendment 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90.pursuant to 10 CFR 50.90, "Application foramendment of license or construction permit,"

if a change to the TS is required.

Furthermore, the requirements of 10 CFR50.59 necessitate that the NRC approve theTS changes before the TS changes areimplemented.

1967 Atomic Energy Commission (AEC)- Revised TS 3.4.15 LCO requiresproposed General Design Criterion 16 -monitoring of reactor coolant pressureMeans shall be provided for monitoring the boundary leakage via containment reactor coolant pressure boundary to detect normal sump level indication, andleakage.

containment atmosphere particulate orgaseous radioactivity monitors.

The plant licensing basis for ONS relative to conformance with NRC design criteria isdiscussed in UFSAR Section 3.1. Since the ONS construction permits (all issued inNovember 1967) preceded the issuance of approved General Design Criteria (Appendix A to 10 CFR Part 50, issued February 1971), the principal design criteria for ONS weredeveloped considering the 70 proposed General Design Criteria (GDC) issued by theAEC in July 1967. Thus, as discussed in UFSAR Section 3.1.16, the RCS leakagedetection instrumentation for ONS was designed to meet AEC-proposed GDC 16,"Monitoring Reactor Coolant Pressure Boundary,"

not 1971-approved GDC 30, "Qualityof reactor coolant pressure boundary."

AEC-proposed GDC 16 states "Means shall beprovided for monitoring the reactor coolant pressure boundary to detect leakage."

Thedesign of ONS allows for a variety of methods to be utilized by control room personnel for monitoring of RCPB leakage as specified in this UFSAR section.

Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Page 8 of 9For non-rupture RCPB leakage, these methods include surveillance of variation fromnormal conditions for:* Reactor Building temperature and sump level.* Reactor Building radioactivity levels.* Condenser off-gas radioactivity levels and Main Steam line monitors (to detectsteam generator tube leakage).

• Decreasing letdown storage tank water level (indicating system leakage).

The 1971-approved GDC 30 contains more requirements than just means to monitor theRCPB to detect leakage.

Although not specifically designed to meet GDC 30, ONS,through its meeting the requirement of AEC-proposed GDC 16, meets the intent of theportion of GDC 30 which states "Means shall be provided for detecting...

reactorcoolant leakage."

Similar to GDC 30, ONS design criteria considerations also pre-dated issuance ofRegulatory Guide (RG) 1.45, Revision 0 (issued May 1973). Thus, conformance withthe regulatory guidance specified in RG 1.45, Revision 0 was not part of the ONSoriginal licensing basis. Regulatory Position C.5 of RG 1.45 states that the sensitivity and response time of each leakage detection system employed for unidentified leakageshould be adequate to detect an RCPB leakage rate, or its equivalent, of onegallon-per-minute (gpm) in less than one hour. While not committed to RG 1.45 as partof the original licensing basis, ONS has credited the capability to meet a'one-gpm-within-one-hour' RCPB leak detection performance criterion in analysessubmitted and approved in support of the licensing position commonly referred to as"leak-before-break (LBB)" (Reference 3). The underlying premise of LBB is thathigh-energy piping systems are designed, constructed, and inspected such that anyflaws in the piping welds would produce a detectable leak and result in plant shutdownlong before the flaw could propagate to the extent that a catastrophic failure of the RCPBwould occur. This position has, in turn, been used to support licensing actions related tovarious ONS activities such as Steam Generator Replacement modifications, Mark BFuel design, Low Pressure Injection System modifications, and Reactor BuildingEmergency Sump strainer replacement modifications (References 3 -7). Thus, thecurrent licensing basis for ONS requires RCS leakage detection instrumentation to becapable of detecting a one gpm leak rate within one hour which is consistent with RG1.45 regulatory guidance.

6 ENVIRONMENTAL CONSIDERATION The proposed change would change a requirement with respect to installation or use of afacility component located within the restricted area, as defined in 10 CFR Part 20, andwould change an inspection or surveillance requirement.

However, the proposed changedoes not involve (i) a significant hazards consideration, (ii) a significant change in the typesor significant increase in the amounts of any effluents that may be released

offsite, or (iii) asignificant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion setforth 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 theproposed change.

Enclosure

-Evaluation of Proposed ChangesLicense Amendment Request No. 2011-03 Page 9 of 97 REFERENCES

1. NRC Letter dated December 19, 2007, "Oconee Nuclear Station, Units 1, 2, and 3,Issuance of Amendments Regarding Removal of the Gaseous Radioactive Monitor fromthe Technical Specifications (TAC NOS. MD4041, MD4042, and MD4043)"

(ADAMSAccession No. ML073241009).

2. NUREG-1 723, "Safety Evaluation Report Related to the License Renewal of OconeeNuclear Station, Units 1, 2, and 3," Section 3.2.7, "Reactor Coolant System Operational Leakage Monitoring."

3. Oconee Nuclear Station Updated Final Safety Analysis Report, Section 5.2.1.9, "LeakBefore Break."4. Oconee Nuclear Station Updated Final Safety Analysis Report, Section 3.6.1.2.1, "CoreFlood/Low Pressure Injection System."5. Oconee Nuclear Station Updated Final Safety Analysis Report, Section 3.9.2.4,"Dynamic System Analysis of the Reactor Internals Under Faulted Conditions (Reference 19)."6. Oconee Nuclear Station Updated Final Safety Analysis Report, Section 5.4.8.6, "LOCARestraints."

7. Oconee Nuclear Station Updated Final Safety Analysis Report, Section 6.3.1,[Emergency Core Cooling System] "Design Bases."

License Amendment Request No. 2011-03ATTACHMENT ITechnical Specification Page Mark-Ups[3 pages following this cover page]NOTE: Attached are markups of existing TS 3.4.15 pages which incorporate the changesdescribed in the Letter Enclosure.

RCS Leakage Detection Instrumentation 3.4.153.4 REACTOR COOLANT SYSTEM (RCS)3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15The following RCS leakage detection instrumentation shall beOPERABLE:

a. One containment normal sump level indication; andb. One containment atmospher Jeuradioactivity APPLICABILITY:

MODES 1, 2, 3, and 4.ACTIONS------------------------------------

11LCO 3.0.4 is not applicable.

r -----------------------------------------------------------

---

CONDITION REQUIRED ACTION COMPLETION TIMEA. [ ontainment A.1 ---------

NOTE -----sumiple l indication Not required until 12inoperabl..

hours afterestablishment of steadystate operation.

F7Capitalize "c" Perform SR 3.4.13.1.

Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sANDA.2 30 dayscontainmrentsump levelindication toOPERABLE status.(continued)

OCONEE UNITS 1, 2, & 33.4.15-1Amendment Nos 1350, 364, & I RCS Leakage Detection Instrumentation 3.4.15ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIMEB. Required containment B.1.1 Analyze grab samples Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />satmosphere of the containment radioactivity monitor atmosphere.

inoperable.

ORB.1.2 --------NOTE -----------

Not required until 12hours afterestablishment ofsteady state operation.

Perform SR 3.4.13.1.

Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sANDB.2 Restore required 30 daysI so containment Insert new Action C atmosphere from Insert A radioactivity monitor toOPERABLE status.Be in MODE 3.Be in MODE 5.12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s36 hoursD. Both required D.1 Enter LCO 3.0.3. Immediately instrument functions operable.

tChange "DOCONEE UNITS 1, 2, & 33.4.15-2Amendment Nos[-e, 30, &3e ONS LAR No. 2011-03Attachment 1 -Technical Specification Page MarkupsInsert A---- ---NOTE --------Only applicable when thecontainment atmosphere gaseous radiation monitor isthe only OPERABLE monitor.C.1 Analyze grab samplesof the containment atmosphere.

ANDC.2 Restore containment sump level indication to OPERABLE status.Once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s7 daysC. Containment sumplevel indication inoperable.

License Amendment Request No. 2011-03ATTACHMENT 2Technical Specification Bases Page Mark-Ups[8 pages following this cover page]NOTE: Attached are markups of existing TS Bases B 3.4.15 pages which incorporate thechanges described in the Letter Enclosure.

RCS Leakage Detection Instrumentation B 3.4.15Insert: "Although ONS is notB 3.4 REACTOR COOLANT SYSTEM (RCS) committed to Regulatory Guide1.45, Revision 0 (Ref. 2) of the RGB 3.4.15 RCS Leakage Detection Instrumentation describes acceptable methods forsetting leakage detection systems."

BASESBACKGROUND ONS Design Criteria (Ref. 1) requires means for detecting RCS LEAKAGE.Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to a grossfailure.

Thus, an early indication or warning signal is necessary to permitproper evaluation of all unidentified LEAKAGE.

• Add Insert BInn, ..-r,, Arn,.,r;,-,

, .r.,km-,nn %.,-.r +l4t6 k, k-k+ra + 1 k ; n r , + A n nnnI uddily bedeece ee ~1t~;.1d VeUM 15Y rnH..rit6ring ehango in Watr9ovol, in HOw rato, 9r in4 the 8proungH@

Trfcgucrlbay OT a puMp.The tor coolant contains radioactivity that, when released to thecontainmeiitheeR be detected by radiation monitoring instrumentation.

rcc,,r ~c r.-.nt rcFadic tivity levels will bc ',cw durin0 in",itill

,cottr ct,"t-'pand fr a ow wokc toroator ntilAc6tr.atd corrocion prodbGtc helve bo8fcFRmcd andI fiB8icn przdoE8t8 appoorF 481`1 fuel elamane~t 8la~dding@-

pontAminatin or cl-adding dofootc.

ARn Onctr-mo.nt cniti'-it,"y of i-9 ..,-,,radioactivity fer pa4ioulete mcHitorig iS pra~tical forF tWiS Ikage det.i,'satm. A radioactivity detection system is included for monitoring d Iparticulate activity because of its sensitivity and rapid response to RCSAdd Insert D LEAKAGE. Ias new 1 Reword this sentence per Insert Cparagraph Air temperature and pressure monitoring methods may also be used toinfer unidentified LEAKAGE to the containment.

Containment temperature

[ Change and pressure fluctuate slightly during unit operation, but a rise above the"are" to "is"j normally indicated range of values may indicate RCS LEAKAGE into thecontainment.

The relevance of temperature and pressure measurements affected by containment free volume and, for temperature, detectorlocation.

Signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressuremonitors are not required by this LCO.Add Insert Eas newparagraph OCONEE UNITS 1, 2, & 3 B 3.4.15-1 BASES REVISION DATED /I ONS LAR No. 2011-03Attachment 2 -Technical Specification Bases Page MarkupsInsert BIn addition to meeting the OPERABILITY requirements, the monitors are typically set to providethe most sensitive response without causing an excessive number of spurious alarms.Insert CRadioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.Insert DOther indications may be used to detect an increase in unidentified LEAKAGE;

however, they arenot required to be OPERABLE by this LCO.Insert E[New paragraph]

The above-mentioned LEAKAGE detection methods or systems differ in sensitivity and responsetime. Some of these systems could serve as early alarm systems signaling the operators thatcloser examination of other detection systems is necessary to determine the extent of anycorrective action that may be required.

RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

APPLICABLE SAFETY ANALYSESThe need to evaluate the severity of an alarm or an indication isimportant to the operators, and the ability to compare and verify withindications from other systems is necessary.

The safety significance of RCS LEAKAGE varies widely depending on itssource, rate, and duration.

Therefore, detecting and monitoring reactorcoolant LEAKAGE into the containment area are necessary.

Separating the identified LEAKAGE from the unidentified LEAKAGE providesquantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and thepublic.RCS leakage detection instrumentation satisfies Criterion 1 ofLCOAdd InsertF as newparagraph posibl RCPB deg~~radation.

Change "leaks" to "amountsab Tn of unidentified LEAKAGE"19",0,ity 9f t ,m ,tO F--r~:,',

.T is LCO requiresinstruments of diverse monitoring princi es to be OPERABLE to provide ahigh d~grfe of confidence that small 4ak are detected in time to allowactions to place the unit in a safe condition when RCS LEAKAGE indicates posil "P derdto. /!Change "OPERABLE" to "available" The LCO requirements are when instruments of diversemeasurement means are GPE, A.'-P Thus, the containment normalsump level indication, in combination with a particulate (RIA-47)radioactivity

monitor, provides an acceptable minimum.I d"or0aseous IAdd "or gaseous (RIA-49)"

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

In MODE 5 or 6, the temperature is 200EFand pressure is maintained low or at atmospheric pressure.

Since the te peratures and pressures arefar lower than those for MODES 1, 2, 3, and 4, th likelihood of leakageand crack propagation is much smaller.

Therefore, he requirements of thisLCO are not applicable in MODES 5 and 6.OCONEE UNITS 1, 2, & 3B 3.4.15-2BASES REVISION DATED .

ONS LAR No. 2011-03Attachment 2 -Technical Specification Bases Page MarkupsInsert F:[New paragraphs]

The LCO requires two instruments of diverse monitoring principles (sump levelindication and atmosphere radioactivity monitoring) to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE.

The containment sump consists of the normal sump and the emergency sump. The LCOrequirements apply to the total amount of unidentified LEAKAGE collected in thenormal sump. The monitor on the containment sump detects level and isinstrumented to detect when there is leakage of 1 gpm. The identification of anincrease in unidentified LEAKAGE will be delayed by the time required for theunidentified LEAKAGE to travel to the containment sump and it may take longerthan one hour to detect a 1 gpm increase in unidentified

LEAKAGE, depending onthe origin and magnitude of the LEAKAGE.

This sensitivity is acceptable forcontainment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the containment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor.

Only one of the two detectors is required to be OPERABLE.

Radioactivity detection systems are included for monitoring both particulate andgaseous activities because of their sensitivities and rapid responses to RCSLEAKAGE, but have recognized limitations.

Reactor coolant radioactivity levelswill be low during initial reactor startup and for a few weeks thereafter, untilactivated corrosion products have been formed and fission products appear fromfuel element cladding contamination or cladding defects.

If there are few fuelelement cladding defects and low levels of activation

products, it may not bepossible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation.

However, the gaseous or particulate containment atmosphere radioactivity monitoris OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in thedesign calculations for the monitors (Ref. 3).

RCS Leakage Detection Instrumentation B 3.4.15Chan.qe "radiation" to "radioactivity" IBASES (continued)

ACTIONSThe Actions are modified by a Note indicating tha the provisions ofLCO 3.0.4 do not apply. As a result, a MODE ct" nge is allowed when thenormal sump level indication and required 2r. monitor are inoperable.

This allowance is provided because other instrumentation is available tomonitor RCS LEAKAGE.Change "atmosphere" to"containment atmosphere radioactivity" A.1 and A.2With the 4r--'i ntainment normal sump level indica ion inoperable, noother form of sampling can provide the equivalent inform tion.However, the containment atmosphere activity monitor provideindications of changes in leakage.

Together with the at4AeGhe1e monitor,the periodic surveillance for RCS inventory

balance, SR 3.4.13.1, waterinventory

balance, must be performed at an increased frequency of24 hours to provide information that is adequate to detect leakage.

A Noteis added allowing that SR 3.4.13.1 is not required to be performed until 12hours after steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, andRCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance providessufficient time to collect and process all necessary data after stable plantconditions are established.

R toration of the, normal sump level indication to OPERABLEstatu i required to regain the function in a Completion Time of 30 daysafter the ,mite's failure.

This time is acceptable considering thefrequency and adequacy of the RCS water inventory balance required byRequired Action A.1.&,1.1 B.1.2, and B.2With" particulate containment atmosphere radioactivity monitoring instrumentation channel inoperable, alternative action is required.

Eithergrab samples of the containment atmosphere must be taken and analyzedor water inventory

balances, in accordance with SR 3.4.13.1, must beperformed to provide alternate periodic information.

With a sampleobtained and analyzed or a water inventory balance performed every24 hours, the reactor may be operated for..upto0 days to allowrestoration of the radioactivity monitor.OCONEE UNITS 1, 2, & 3B 3.4.15-3BASES REVISION DATED -

RCS Leakage Detection Instrumentation B 3.4.15BASESACTIONSB.1.1, B.1.2, and B.2 (continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval for SR 3.4.13.1 provides periodic information that isadequate to detect leakage.

A Note is added allowing that SR 3.4.13.1 isnot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeuptank levels, makeup and letdown, and RCP seal injection and return flows).The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established.

The 30 dayCompletion Time recognizes at least one other form of leak detection is 1,, WAdd Insert G asnew paragraph Change "C.1 and C.2" to Change "A or B""D' an 0--a- '. toha g " A rBA, B, or C""D.1 and D.2"If a Required Action of Condition cannot be met within the requiredCompletion Time, the unit must be brought to a MODE in which the LCOdoes not apply. To achieve this status, the unit must be brought to at leastMODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowedCompletion Times are reasonable, based on operating experience, toreach the required unit conditions from full power conditions in an orderlymanner and without challenging unit systems.Change "D. toIf both required leakage detection instruments are inoperable, no automatic means of monitoring leakage are available, an immediate plant shutdownin accordance with LCO 3.0.3 is required.

SURVEILLANCE REQUIREMENTS SR 3.4.15.1Add "(normal sump level indication andcontainment atmosphere radioactivity monitor)"

SR 3.4.15.1 requires the performance of a CHANNEL CHECK of therequired containment atmosphere radioactivity monitor.

The check givesreasonable confidence that 4he channel is operating properly.

TheSurveillance Frequency is base n operating experience, equipment reliability, and plant risk and is conilied under the Surveillance Frequency Control Program.Change "the"to "each"D]OCONEE UNITS 1, 2, & 3B 3.4.15-4BASES REVISION DATE E, ONS LAR No. 2011-03Attachment 2 -Technical Specification Bases Page MarkupsInsert G:C.1 and C.2With containment normal sump level indication inoperable, the only means ofdetecting LEAKAGE is the required containment atmosphere radioactivity monitor.A Note clarifies that this Condition is applicable when the only OPERABLE monitoris the containment atmosphere gaseous radioactivity monitor.

The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leakwithin one hour when RCS activity is low. In addition, this configuration does notprovide the required diverse means of leakage detection.

Indirect methods ofmonitoring RCS leakage must be implemented.

Grab samples of the containment atmosphere must be taken and analyzed to provide alternate periodic information.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage.

The RequiredAction provides 7 days to restore another RCS leakage monitor to OPERABLEstatus to regain the intended leakage detection diversity.

The 7 day Completion Time ensures that the unit will not be operated in a degraded configuration for alengthy time period.

RCS Leakage Detection Instrumentation B 3.4.15BASESSURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONAL TESTof the required containment atmosphere radioactivity monitor.

The testensures that the monitor can perform its function in the desired manner.The test verifies the alarm setpoint and relative accuracy of the instrument string. ISR 3.4.15.3 and SR 3.4.15.4These SRs require the performance of a CHANNEL CALIBRATION foreach of the required RCS leakage detection instrumentation channels.

Thecalibration verifies the accuracy of the instrument string, including theinstruments located inside containment.

The Surveillance Frequency isbased on operating experience, equipment reliability, and plant risk and icontrolled under the Surveillance Frequency Control Program.REFERENCES

1. UFAR, ectio Change "3.1" to "3.1.16,

'Criterion 16 -1. UFSAR, Section Reactor Coolant Pressure2 1 ,R Boundary (Category B)."'Add new Reference 3 as follows:"3. UFSAR, Section 5.2.3.10.5, "Leak Detection."

-EChange "10 CFR 50.36" to "Regulatory Guide 1.45, Revision 0, 'Reactor CoolantPressure Boundary Leakage Detection System,'

May 1973."OCONEE UNITS 1, 2, & 3B 3.4.15-5BASES REVISION DATEEý License Amendment Request No. 2011-03ATTACHMENT 3Retyped Technical Specification Pages[3 pages following this cover page]NOTE: Attached are clean, retyped TS Pages 3.4.15-1,

-2 and -3.

RCS Leakage Detection Instrumentation 3.4.153.4 REACTOR COOLANT SYSTEM (RCS)3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment normal sump level indication; andb. One containment atmosphere radioactivity monitor (gaseous orparticulate).

APPLICABILITY:

MODES 1, 2, 3, and 4.ACTIONS-NOTE.LCO 3.0.4 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIMEA. Containment sump A.1 ----------

NOTE-----

level indication Not required until 12inoperable, hours afterestablishment of steadystate operation.

Perform SR 3.4.13.1.

Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sANDA.2 Restore containment 30 dayssump level indication toOPERABLE status.(continued)

OCONEE UNITS 1, 2, & 33.4.15-1Amendment Nos. __, -, & I RCS Leakage Detection Instrumentation 3.4.15CONDITION REQUIRED ACTION COMPLETION TIMEB. Required containment B.1.1 Analyze grab samples Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />satmosphere of the containment radioactivity monitor atmosphere.

inoperable.

ORB.1.2--------

NOTE -----Not required until 12hours afterestablishment ofsteady state operation.

Perform SR 3.4.13.1.

Once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sANDB.2 Restore required 30 dayscontainment atmosphere radioactivity monitor toOPERABLE status.C. -------- NOTE ----------

C.1 Analyze grab samples of Once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />sOnly applicable when the containment the containment atmosphere.

atmosphere gaseousradiation monitor is the ANDonly OPERABLEmonitor.

C.2 Restore containment 7 dayssump level indication toContainment sump OPERABLE status.level indication inoperable.

D. Required Action and D.1 Be in MODE 3. 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />sassociated Completion Time not met. ANDD.2 Be in MODE 5. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />sOCONEE UNITS 1, 2, & 33.4.15-2Amendment Nos. _, -, I RCS Leakage Detection Instrumentation 3.4.15SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of required In accordance with thecontainment atmosphere radioactivity monitor.

Surveillance Frequency Control ProgramSR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of In accordance with therequired containment atmosphere radioactivity Surveillance Frequency monitor.

Control ProgramSR 3.4.15.3 Perform CHANNEL CALIBRATION of In accordance with therequired containment sump level indication.

Surveillance Frequency Control ProgramSR 3.4.15.4 Perform CHANNEL CALIBRATION of In accordance with therequired containment atmosphere radioactivity Surveillance Frequency monitor.

Control ProgramOCONEE UNITS 1, 2, & 33.4.15-3Amendment Nos. -, -, I License Amendment Request No. 2011-03ATTACHMENT 4Retyped Technical Specification Bases Pages[6 pages following this cover page]NOTE: Attached are clean, retyped TS Bases Pages B 3.4.15-1 through B 3.4.15-6.

RCS Leakage Detection Instrumentation B 3.4.15B 3.4 REACTOR COOLANT SYSTEM (RCS)B 3.4.15 RCS Leakage Detection Instrumentation BASESBACKGROUND ONS Design Criteria (Ref. 1) requires means for detecting RCS LEAKAGE.Although ONS is not committed to Regulatory Guide 1.45, Revision 0(Ref. 2) describes acceptable methods for setting leakage detection systems.Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon afteroccurrence as practical to minimize the potential for propagation to a grossfailure.

Thus, an early indication or warning signal is necessary to permitproper evaluation of all unidentified LEAKAGE.

In addition to meeting theOPERABILITY requirements, the monitors are typically set to provide themost sensitive response without causing an excessive number of spuriousalarms.The reactor coolant contains radioactivity that, when released to thecontainment, may be detected by radiation monitoring instrumentation.

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses toRCS LEAKAGE.Other indications may be used to detect an increase in unidentified LEAKAGE;

however, they are not required to be OPERABLE by this LCO.Air temperature and pressure monitoring methods may be used to inferunidentified LEAKAGE to the containment.

Containment temperature andpressure fluctuate slightly during unit operation, but a rise above thenormally indicated range of values may indicate RCS LEAKAGE into thecontainment.

The relevance of temperature and pressure measurements is affected by containment free volume and, for temperature, detectorlocation.

Signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressuremonitors are not required by this LCO.The above-mentioned LEAKAGE detection methods or systems differ insensitivity and response time. Some of these systems could serve as earlyalarm systems signaling the operators that closer examination of otherdetection systems is necessary to determine the extent of any corrective action that may be required.

OCONEE UNITS 1, 2, & 3B 3.4.15-1BASES REVISION DATED / / I RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY ANALYSES to the operators, and the ability to compare and verify with indications fromother systems is necessary.

The safety significance of RCS LEAKAGE varies widely depending on itssource, rate, and duration.

Therefore, detecting and monitoring reactorcoolant LEAKAGE into the containment area are necessary.

Separating the identified LEAKAGE from the unidentified LEAKAGE providesquantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and thepublic.RCS leakage detection instrumentation satisfies Criterion 1 of10 CFR 50.36.LCO This LCO requires instruments of diverse monitoring principles to beOPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the unit in a safecondition when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires two instruments of diverse monitoring principles (sumplevel indication and atmosphere radioactivity monitoring) to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE.

Thecontainment sump consists of the normal sump and the emergency sump.The LCO requirements apply to the total amount of unidentified LEAKAGEcollected in the normal sump. The monitor on the containment sumpdetects level and is instrumented to detect when there is leakage of 1 gpm.The identification of an increase in unidentified LEAKAGE will be delayedby the time required for the unidentified LEAKAGE to travel to thecontainment sump and it may take longer than one hour to detect a 1 gpmincrease in unidentified

LEAKAGE, depending on the origin and magnitude of the LEAKAGE.

This sensitivity is acceptable for containment sumpmonitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to thecontainment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor.

Only one of the two detectors is requiredto be OPERABLE.

Radioactivity detection systems are included formonitoring both particulate and gaseous activities because of theirsensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations.

Reactor coolant radioactivity levels will be low during initialreactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel elementcladding contamination or cladding defects.

If there are few fuel elementcladding defects and low levels of activation

products, it may not beOCONEE UNITS 1, 2, & 3B 3.4.15-2BASES REVISION DATED / /

RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

LCO (continued) possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> duringnormal operation.

However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable ofdetecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> givenan RCS activity equivalent to that assumed in the design calculations forthe monitors (Ref. 3).The LCO requirements are satisfied when instruments of diversemeasurement means are available.

Thus, the containment normal sumplevel indication, in combination with a particulate (RIA-47) or gaseousradioactivity monitor (RIA-49),

provides an acceptable minimum.APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3,and 4, RCS leakage detection instrumentation is required to beOPERABLE.

In MODE 5 or 6, the temperature is < 200OF and pressure is maintained low or at atmospheric pressure.

Since the temperatures and pressures arefar lower than those for MODES 1, 2, 3, and 4, the likelihood of leakageand crack propagation is much smaller.

Therefore, the requirements of thisLCO are not applicable in MODES 5 and 6.ACTIONS The Actions are modified by a Note indicating that the provisions ofLCO 3.0.4 do not apply. As a result, a MODE change is allowed when thenormal sump level indication and required radioactivity monitor areinoperable.

This allowance is provided because other instrumentation isavailable to monitor RCS LEAKAGE.A.1 and A.2With the containment normal sump level indication inoperable, no otherform of sampling can provide the equivalent information.

However, the containment atmosphere activity monitor will provideindications of changes in leakage.

Together with the containment atmosphere radioactivity

monitor, the periodic surveillance for RCSinventory

balance, SR 3.4.13.1, water inventory

balance, must beperformed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage.

A Note is added allowing that SR3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady stateoperation (stable RCS pressure, temperature, power level, pressurizer andmakeup tank levels, makeup and letdown, and RCP seal injection andreturn flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect andOCONEE UNITS 1, 2, & 3B 3.4.15-3BASES REVISION DATED / 1 I RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

ACTIONS A.1 and A.2 (continued) process all necessary data after stable plant conditions are established.

Restoration of the normal sump level indication to OPERABLE status isrequired to regain the function in a Completion Time of 30 days after levelindication failure.

This time is acceptable considering the frequency andadequacy of the RCS water inventory balance required by RequiredAction A. 1.B.1.1, B.1.2, and B.2With required gaseous or particulate containment atmosphere radioactivity monitoring instrumentation channel inoperable, alternative action isrequired.

Either grab samples of the containment atmosphere must betaken and analyzed or water inventory

balances, in accordance withSR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or a water inventory balanceperformed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 daysto allow restoration of the radioactivity monitor.The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval for SR 3.4.13.1 provides periodic information that isadequate to detect leakage.

A Note is added allowing that SR 3.4.13.1 isnot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeuptank levels, makeup and letdown, and RCP seal injection and return flows).The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process allnecessary data after stable plant conditions are established.

The 30 dayCompletion Time recognizes at least one other form of leak detection isavailable.

C.1 and C.2With containment normal sump level indication inoperable, the only meansof detecting LEAKAGE is the required containment atmosphere radioactivity monitor.

A Note clarifies that this Condition is applicable whenthe only OPERABLE monitor is the containment atmosphere gaseousradioactivity monitor.

The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within one hour when RCSactivity is low. In addition, this configuration does not provide the requireddiverse means of leakage detection.

Indirect methods of monitoring RCSleakage must be implemented.

Grab samples of the containment atmosphere must be taken and analyzed to provide alternate periodicinformation.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCSleakage.

The Required Action provides 7 days to restore another RCSOCONEE UNITS 1, 2, & 3B 3.4.15-4BASES REVISION DATED / I RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

ACTIONS C.1 and C.2 (continued) leakage monitor to OPERABLE status to regain the intended leakagedetection diversity.

The 7 day Completion Time ensures that the unit willnot be operated in a degraded configuration for a lengthy time period.D.1 and D.2If a Required Action of Condition A, B or C cannot be met within therequired Completion Time, the unit must be brought to a MODE in whichthe LCO does not apply. To achieve this status, the unit must be broughtto at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Theallowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderlymanner and without challenging unit systems.E. 1If both required leakage detection instruments (normal sump levelindication and containment atmosphere radioactivity monitor) areinoperable, no automatic means of monitoring leakage are available, andimmediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of therequired containment atmosphere radioactivity monitor.

The check givesreasonable confidence that each channel is operating properly.

TheSurveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.SR 3.4.15.2SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONAL TESTof the required containment atmosphere radioactivity monitor.

The testensures that the monitor can perform its function in the desired manner.The test verifies the alarm setpoint and relative accuracy of the instrument string.OCONEE UNITS 1, 2, & 3B 3.4.15-5BASES REVISION DATED / / I RCS Leakage Detection Instrumentation B 3.4.15BASES (continued)

SURVEILLANCE SR 3.4.15.3 and SR 3.4.15.4REQUIREMENTS (continued)

These SRs require the performance of a CHANNEL CALIBRATION foreach of the required RCS leakage detection instrumentation channels.

Thecalibration verifies the accuracy of the instrument string, including theinstruments located inside containment.

The Surveillance Frequency isbased on operating experience, equipment reliability, and plant risk and iscontrolled under the Surveillance Frequency Control Program.REFERENCES

1. UFSAR, Section 3.1.16, "Criterion 16 -Monitoring Reactor CoolantPressure Boundary (Category B)."2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant PressureBoundary Leakage Detection System,"

May 1973.3. UFSAR, Section 5.2.3.10.5, "Leak Detection."

OCONEE UNITS 1, 2, & 3B 3.4.15-6BASES REVISION DATED / / I