ML18235A107

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APR1400-K-O-NR-14001-NP, Rev. 3, Deviation Report Between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications.
ML18235A107
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Site: 05200046
Issue date: 08/31/2018
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Korea Hydro & Nuclear Power Co, Ltd
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Office of New Reactors
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APR1400-K-O-NR-14001-NP, Rev 3
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{{#Wiki_filter:Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications Revision 3 Non-Proprietary August 2018 Copyright © 2018 Korea Electric Power Corporation & Korea Hydro & Nuclear Power Co., Ltd. All Rights Reserved KEPCO & KHNP

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 REVISION HISTORY Revision Date Page Description 0 October 2014 All Original Issued 1 November 2015 All Complete Revision 2 March 2018 All Complete Revision 3 August 2018 All Complete Revision This document was prepared for the design certification application to the U.S. Nuclear Regulatory Commission and contains technological information that constitutes intellectual property of Korea Hydro & Nuclear Power Co., Ltd. Copying, using, or distributing the information in this document in whole or in part is permitted only to the U.S. Nuclear Regulatory Commission and its contractors for the purpose of reviewing design certification application materials. Other uses are strictly prohibited without the written permission of Korea Electric Power Corporation and Korea Hydro & Nuclear Power Co., Ltd. KEPCO & KHNP i

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 ABSTRACT The APR1400 Technical Specifications presented in Chapter 16 of the DCD are based on NUREG-1432, Rev. 4.0, Standard Technical Specifications - Combustion Engineering Plants, by reference. This report provides the justification for the technical deviations from NUREG-1432 and the APR1400 Technical Specifications. KEPCO & KHNP ii

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 TABLE OF CONTENTS I. INTRODUCTION ****************************************************************************** 1 II. GENERAL DESCRIPTION OF DEVIATIONS ***************************************** 2

1. USE OF CONSERVATIVE VALUES ************************************************ 2
2. USE OF ADDITIONAL DEFINITIONS *********************************************** 5
3. USE OF CURRENT TECH. SPEC. ************************************************** 7
4. CORE OPERATING LIMITS REPORT ITEMS ************************************ 8
5. DIFFERENT NAME OF SYSTEMS/COMPONENTS **************************** 8
6. TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELERS ***** 9 III. SYSTEM LEVEL DEVIATIONS AND JUSTIFICATION **************************** 13
1. INSTRUMENTATION ****************************************************************** 13
2. REACTOR COOLANT SYSTEM **************************************************** 16
3. EMERGENCY CORE COOLING SYSTEM ************************************** 17
4. ELECTRICAL POWER SYSTEMS ************************************************* 20
5. REFUELING OPERATION *********************************************************** 22
6. CONTAINMENT SYSTEM************************************************************ 24
7. PLANT SYSTEM ************************************************************************ 25 IV. CONCLUSIONS **************************************************************************** 185 V. REFERENCES ***************************************************************************** 186 KEPCO & KHNP iii

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 LIST OF TABLE Table II-1 Conservative values in TS SRs that are different than NUREG-1432***** 3 Table II-2 Conservative values in LCOs that are different than NUREG-1432 ************ 4 Table II-3 Name of system and components that are different than NUREG-1432****** 8 Table II-4 TSTFs Included in NUREG-1432 Rev. 4 that are not included in APR1400 ***

             ******************************************************************************************** ****** 10 Table II-5   APR1400 status of TSTFs that have been approved since NUREG-1432 Rev. 4 **************************************************************************************** ***11 Table III-1  Deviations and Justification between Standard Technical Specifications and the APR1400 Technical Specifications *********************************************** 27 KEPCO & KHNP                                                                                                         iii

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 ACRONYMS AND ABBREVIATIONS ABCAEES Auxiliary Building Controlled Area Emergency Exhaust System AC Alternating Current ACU Air Cleaning Unit ADV Atmospheric Dump Valve ALT As-Left Tolerance AFAS Auxiliary Feedwater Actuation Signal AFT As-Found Tolerance AFW(S) Auxiliary Feedwater (System) AFWST Auxiliary Feedwater Storage Tank AMI Accident Monitoring Instrumentation APC-S Auxiliary Process Cabinet - Safety ASI AXIAL SHAPE INDEX AV Allowable Value BA Burnable Absorbers BAMP Boric Acid Makeup Pump BAST Boric Acid Storage Tank BDAS Boron Dilution Alarm Systems CCAS Containment Cooling Actuation Signal CCW(S) Component Cooling Water (System) CEA(C) Control Element Assembly (Calculator) CEDMCS Control Element Drive Mechanism Control System CFT CHANNEL FUNCTIONAL TEST CIV Containment Isolation Valve COL Construction and Operation License COLR CORE OPERATING LIMITS REPORT COLSS Core Operating Limit Supervisory System CPC Core Protection Calculator CPCS Core Protection Calculator System CPIS Containment Purge Isolation System CPIAS Containment Purge Isolation Actuation System CRE Control Room Envelope CREACS Control Room Emergency (Makeup) Air Cleanup System CREATCS Control Room Emergency Air Temperature Control System CREVAS Control Room Emergency Ventilation Actuation System CRHS Control Room HVAC System KEPCO & KHNP vi

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 CRIS Control Room Isolation CRSRS Control Room Supply and Return System CSAS Containment Spray Actuation Signal CS(P) Containment Spray (Pump) CSHX Containment Spray Heat Exchanger CSS Containment Spray System CST Condensate Storage Tank CTS Current Technical Specifications DBA Design Basis Accident DC Direct Current DCD Design Control Document DE DOSE EQUIVALENT DG Diesel Generator DNB(R) Departure from Nucleate Boiling (Ratio) DPS Diverse Protection System DRCS Digital Rod Control System DVI Direct Vessel Injection ECCS Emergency Core Cooling System ECW(S) Essential Chilled Water (System) EDG Emergency Diesel Generator EFAS Emergency Feedwater Actuation Signal EFPD Effective Full Power Days ENFMS Ex-core Neutron Flux Monitoring System EOG Emergency Operational Guideline ESFAS Engineered Safety Features Actuation System ESF-CCS Engineered Safety Features - Component Control System ESW(S) Essential Service Water (System) FBACS Fuel Building Air Cleanup System FHAEES Fuel Handling Area Emergency Exhaust System FHEVAS Fuel Handling Area Ventilation Actuation System FHIS Fuel Handling Isolation Signal FSAR Final Safety Analysis Report GCB Generator Circuit Breaker HMS Hydrogen Mixing System HPSI(P) High Pressure Safety Injection (Pump) HVAC Heating, Ventilation, and Air Conditioning HVT Holdup Volume Tank KEPCO & KHNP vi

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 I&C Instrumentation and Control ICS Iodine Cleanup System IRWST In-Containment Refueling Water Storage Tank KHNP Korea Hydro & Nuclear Co., Ltd LC Load Center LCO Limiting Condition for Operation LHR Linear Heat Rate LOCA Loss Of Coolant Accident LOOP Loss Of Offsite Power LOVS Loss of Voltage Start LPD Local Power Density LPSI(P) Low Pressure Safety Injection (Pump) LTOP Low Temperature Overpressure Protection MCC Motor Control Center MCR Main Control Room MFIV Main Feedwater Isolation Valve MG Main Generator MSADV Main Steam Atmospheric Dump Valve MSIS Main Steam Isolation Signal MSIV Main Steam Isolation Valve MSSV Main Steam Safety Valves MTC Moderator Temperature Coefficient NPP Nuclear Power Plant NTSP Nominal Trip Setpoint OPP Over Pressure Protection PAM Post Accident Monitoring PIV Pressure Isolation Valve PORV Power Operated Relief Valves POSRV Pilot Operated Safety Relief Valve PPS Plant Protection System PREACS Pump Room Exhaust Air Cleanup System PTLR PRESSURE AND TEMPERATURE LIMITS REPORT PZR Pressurizer RCGV(S) Reactor Coolant Gas Vent (System) RCP Reactor Coolant Pump KEPCO & KHNP vi

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 RCPB Reactor Coolant Pressure Boundary RCS Reactor Coolant System RG Regulatory Guide RHR Residual Heat Removal RITS Risk Informed Technical Specification RITSTF Risk Informed Technical Specification Task Force RPCS Reactor Power Cutback System RPS Reactor Protection (Protective) System RSPT Reed Switch Position Transmitter RSR Remote Shutdown Room RTCB Reactor Trip Circuit Breaker RTD Resistance Thermal Detector RTP RATED THERMAL POWER RTS Reactor Trip System RTSS Reactor Trip Switchgear System RWT Refueling Water Tank SAT Standby Auxiliary Transformer SBEACS Shield Building Exhaust Air Cleanup System SBO Station Black Out SC(P) Shutdown Cooling (Pump) SCS Shutdown Cooling System SDC Shutdown Cooling SDM SHUTDOWN MARGIN SFHM Spent Fuel Handling Machine SFP Spent Fuel Pool SFPCCS Spent Fuel Pool Cooling and Cleanup System SFPWL Spent Fuel Pool Water Level SG Steam Generator SI(P) Safety Injection (Pump) SIAS Safety Injection Actuation Signal SIS Safety Injection System SIT Safety Injection Tank SL Safety Limit SR Surveillance Requirement SRM Source Range Monitor SRP Standard Review Plan STE Special Test Exceptions STS Standard Technical Specifications SWS Service Water System TS Technical Specifications TSTF Technical Specifications Task Force TSP Trisodium Phosphate UAT Unit Auxiliary Transformer UHS Ultimate Heat Sink VOPT Variable Overpower Trip KEPCO & KHNP vi

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 I. INTRODUCTION The APR1400 Technical Specifications satisfy 10 CFR 50.36 (Reference 1), "Technical specifications" and applies NUREG-1432, Rev. 4.0 (Reference 2) as the Standard Technical Specifications (STS). The difference between the STS and the APR1400 Technical Specifications exists only as necessary to reflect advanced design features and to incorporate operational experience into the APR1400. This report provides the justification for the deviations of APR1400 Technical Specifications compared to the Standard Technical Specifications (NUREG-1432, Rev. 4.0). KEPCO & KHNP 1

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 II. GENERAL DEVIATIONS AND JUSTIFICATION 1 Use of Conservative Values The APR1400 design has been developed based on operating and licensing experiences in Korea. Such experiences are reflected in the APR1400 Technical Specifications. The APR1400 Technical Specifications are not considered to be risk informed technical specifications (RITS). Thus, some values such as completion times and frequencies are more conservative than those in NUREG-1432. Table II-1 below shows the difference in values for surveillances (such as frequencies) and Table II-2 shows LCO values (such as completion times). These differences in values between the APR1400 TS and those of NUREG-1432 are conservative and therefore do not require justification. Though the section listed for the APR1400 might have a different number than that of NUREG-1432, it is considered to be the equivalent specification. These lists are not repeated in Table III-1. KEPCO & KHNP 2

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Table II-1 Conservative values in TS SRs that are different than NUREG-1432 NUREG-1432 APR1400 TS Remark SR Section Value SR Section Value N/A N/A 3.1.1.2 24 hours N/A N/A 3.1.1.3 24 hours N/A N/A 3.1.7.2 24 hours RITS not applied N/A N/A 3.1.8.1 12 hours RITS not applied 3.1.8.2 7 days 3.1.9.2 24 hours RITS not applied N/A N/A 3.1.9.3 2 hours APR1400 specific condition for STE N/A N/A 3.1.9.4 12 hours APR1400 specific condition for STE N/A N/A 3.1.11.1 15 minutes APR1400 specific condition for STE N/A N/A 3.1.11.2 15 minutes APR1400 specific condition for STE N/A N/A 3.1.12.1 12 hours RITS not applied 3.2.2.1 70% RTP 3.2.2.1 80% RTP APR1400 specific condition 3.3.1.7 92 days 3.3.1.7 31 days 3.3.1.8 92 days 3.3.1.8 31 days 3.3.1.12 70% RTP 3.3.1.11 80% RTP APR1400 specific condition 3.3.1.13 92 days 3.3.1.12 31 days RITS not applied 3.3.2.2 92 days 3.3.2.2 31 days RITS not applied 3.3.2.3 92 days 3.3.2.3 31 days RITS not applied 3.3.3.3 92 days 3.3.3.3 31 days RITS not applied 3.3.4.2 92 days 3.3.4.1 31 days RITS not applied 3.3.4.4 Once within 7 3.3.4.3 31 days RITS not applied days prior to each reactor startup 3.3.5.2 92 days 3.3.5.2 31 days RITS not applied 3.3.5.5 92 days 3.3.5.5 31 days RITS not applied 3.3.6.1 92 days 3.3.6.1 31 days RITS not applied 3.3.6.2 184 days 3.3.6.2 31 days on a RITS not applied STAGGERED TEST BASIS 3.3.6.3 18 months 3.3.6.1 31 days RITS not applied 3.3.13.2 92 days 3.3.13.2 31 days RITS not applied 3.4.9.2 18 months 3.4.9.2 92 days RITS not applied 3.4.15.2 92 days 3.4.14.3 31 days 3.9.3.1 None 3.9.3.1 100 hours prior to the 7 days start of movement of irradiated fuel Once per 7 days N/A N/A 3.9.7.1 7 days RITS not applied KEPCO & KHNP 3

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Table II-2 Conservative values in LCOs that are different than NUREG-1432 NUREG-1432 APR1400 TS Remark LCO Value LCO Section Value Section N/A N/A 3.1.12 A.1 Immediately 3.1.12 A.2 Immediately 3.1.12 A.3 4 hours 3.2.3 B.2 16 hours 3.2.3 B.2 8 hours CTS value used 3.4.13 b 1 gpm 3.4.12 b 0.5 gpm APR1400 specific condition for STE (DCD 15.1.5) 3.5.1 B.1 24 hours 3.5.1 B.1 1 hour RITS not applied 3.5.2 A.1 7 days 3.5.2 A.1 72 hours RITS not applied 3.7.12 A.1 30 days 3.7.12 A.1 7 days KEPCO & KHNP 4

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 2 Use of Additional Definition In the APR1400 TS, the following terminologies are defined to provide a clearer understanding relative to its application to the APR1400 design. 2.1 CORE ALTERATION In NUREG-1432, CORE ALTERATION is not included in the Definitions section of TS. Instead, the following statement is used: movement of [recently] irradiated fuel assemblies within containment. In the APR1400 TS, CORE ALTERATION is defined as follows to provide a more precise definition: CORE ALTERATION shall be the movement or manipulation of any fuel, sources, reactivity control components, or other components (excluding control element assemblies (CEAs) withdrawn into the upper guide structure) affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position. APR1400 TS LCOs 3.3.8, 3.3.9, 3.9.3 and 3.9.6 are related to this deviation. 2.2 DOSE EQUIVALENT I-131 and XE-133 In NUREG-1432, DOSE EQUIVALENT I-131 (DE I-131) and -AVERAGE DISINTEGRATION ENERGY are defined as follows; DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in [Table III of TID-14844, AEC, 1962, Calculation of Distance Factors for Power and Test Reactor Sites, or those listed in Table E-7 of Regulatory Guide 1.109, Rev. 1, NRC, 1977, or ICRP 30, Supplement to Part 1, page 192-212, Table titled, Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity]. KEPCO & KHNP 5

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives > [15] minutes, making up at least 95% of the total noniodine activity in the coolant. In the APR1400 TS, the definition of DE I-131 is consistent with TSTF-490, Rev. 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec. TSTF-490 recommends the following changes: 1) revise the definition of DE I-131, 2) delete the definition of E-Bar, 3) add a new definition for DE Xe-133, and 4) revise LCO 3.4.16, RCS Specific Activity. DOSE EQUIVALENT I-131 and XE-133 are defined as follows in the APR1400 TS; DOSE EQUIVALENT I-131 shall be that concentration of I-131 (Bq/g) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes I-131, I-132, I-133, I-134, and I-135 actually present. The determination of DOSE EQUIVALENT I-131 shall be performed using thyroid dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, EPA-520/1-88-020, September 1988. DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (Bq/g) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135 and Xe-138 actually present. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, External Exposure to Radionuclides in Air, Water, and Soil, EPA 402-R-93-081, September 1993. APR1400 TS LCO 3.4.15 is related to this deviation. 2.3 OPERABLE - OPERABILITY In NUREG-1432, the term 'division' has not been used. In the APR1400 TS, 'division' is added and used which is defined as follows. A division is a set of trains, performing various safety functions, separated both mechanically and electrically from another division. The separation between the divisions is provided geographically KEPCO & KHNP 6

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 or by physical barrier. The Class 1E onsite power system consists of two redundant divisions (Division 1 and Division 2) and each division is further broken down into Train A and Train C for Division 1 and Trains B and D for Division 2. 3 Use of current Tech. Spec. There are 23 operating NPPs in Korea which use Current Technical Specifications (CTS). When CTS is considered with the STS, some definitions, statements, and classifications were kept in accordance with CTS to maintain consistency with the operating experience of those plants. 3.1 Operational MODE classification When an operational MODE is defined, NUREG-1432 uses RCS average temperature whereas the APR1400 TS uses RCS cold leg temperature. APR1400 TS Table 1.1-1 and LCO 3.4.2 are related to this deviation. 3.2 Days of 1 month NUREG-1432 uses 30 days as a definition of 1 month whereas APR1400 TS uses 31 days. Completion Times in APR1400 TS LCOs 3.3.11, 3.3.12, 3.6.2, 3.6.3 and 3.8.6 and Surveillance Frequencies for numerous APR1400 TS LCOs are related on this deviation. 3.3 End States TSTF-422 Risk-Informed Modification to Selected Action End States for CEOG PWRs is not applied because the APR1400 design-specific analysis for modification of end state was not performed. Therefore, MODE 5 is defined as the safe end state in the APR1400 TS. Required Actions and/or Completion Times in APR1400 TS LCOs 3.3.5, 3.3.6, 3.3.8, 3.3.9, 3.6.2, 3.6.3, 3.6.4, 3.6.5, 3.6.6, 3.7.7, 3.7.8, 3.7.9, 3.7.10, 3.7.11, 3.7.12, 3.8.1, 3.8.4 and 3.8.7 are related to this deviation. KEPCO & KHNP 7

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 4 Core Operating Limits Report Items In the APR1400 TS, some parameters are described based on input parameters of the DCD Chapter 15 safety analysis, whereas NUREG-1432 defines these parameters as being provided in the COLR. These deviations are listed below.

    -    LCO 3.1.1 SHUTDOWN MARGIN (SDM)
    -    LCO 3.1.3 MTC limits and associated surveillance requirements
    -    LCO 3.4.1 DNB parameters and associated surveillance requirements
    -    LCO 3.4.9 Pressurizer water level ranges
    -    LCO 3.4.10 Pressurizer safety valve setpoints 5         Different Name of Systems/Components The APR1400 TS uses some different system or component names from NUREG-1432, though the meaning is the same. The following list (Table II-3) shows these items which are generally not included in Table III-1.

Table II-3 Name of system and components that are different than NUREG-1432 NUREG-1432 Related APR1400 TS Related Remark Sections Sections Full/Part length 1.1, 3.1.4, Full/Part 1.1, 3.1.4, CEA 3.1.7, 3.1.8, Strength CEA 3.1.7, 3.1.9, 3.1.9, 3.3.3, 3.1.10, 3.1.11, 3.3.3, 4.2.2, 5.6.3 CRIS 3.3.9, 5.5.19 CREVAS 3.3.9, 5.5.19 CPIS 3.3.8, 5.5.19 CPIAS 3.3.8, 5.5.19 FHIS 3.3.10, 5.5.19 FHEVAS 3.3.10, 5.5.19 Remote 3.3.12 Remote 3.3.12 Shutdown Shutdown System Display and Control PAM 3.3.11, 5.6.5 AMI 3.3.11, 5.6.5 RWT 3.5.4, 3.5.5 IRWST 3.3.11, 3.3.12, 3.4.16, 3.5.2, 3.5.4, 3.5.5 KEPCO & KHNP 8

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 NUREG-1432 Related APR1400 TS Related Remark Sections Sections Containment 3.6.6 Containment 3.6.6, 5.5.2 Containment Spray and Spray System Cooling Cooling System function is included in the Containment Spray System ADV 3.7.4 MSADV 3.7.4, 3.3.11, 3.3.12 Service Water 3.7.8 Essential 3.3.12, 3.7.8 System Service Water System ECW 3.7.10 ECWS 3.7.10 PREACS 3.7.13, 3.7.15 ABCAEES 3.7.12, 5.5.11 FBACS 3.3.10, 3.7.14 FHAEES 3.7.13, 5.5.11 FHIS 3.3.10, 5.5.19 FHEVAS 3.3.10, 5.5.19 DG 1.1, 3.3.7, EDG 1.1, 3.3.7, 3.8.1, 3.8.2, 3.3.12, 3.8.1, 3.8.3, 5.5.19 3.8.2, 3.8.3, 5.5.19 Battery 3.8.6 Battery Cell 3.8.6 Parameters Parameters 6 Technical Specifications Task Force (TSTF) Travelers The APR1400 TS adopts the approved technical specifications task force travelers that are included in NUREG-1432 Rev. 4. TSTFs that are not included in the APR1400 TS are indicated in Table II-4 with technical rationale. APR1400 TS status of applicable TSTF travelers that have been approved since NUREG-1432 Rev. 4 is indicated in Table II-5. KEPCO & KHNP 9

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Table II-4 TSTFs included in NUREG-1432 Rev. 4 that are not included in APR1400 Approved TSTF Short Title Status for Technical Rationale Traveler APR1400 TSTF-30-A, Rev. 3 Extend the Not Risk Informed Technical Completion Time for Incorporated Specification is not inoperable isolation applied. Instead, valve to a closed NUREG-1432 Rev. 1 is system to 72 hours used. TSTF-51-A, Rev. 3 Revise containment Not Risk Informed Technical requirements during Incorporated Specification is not handling irradiated applied. Instead, fuel and core NUREG-1432 Rev. 1 is alterations used. TSTF-68-A, Rev. 2 Containment Not Risk Informed Technical Personnel Airlock Incorporated Specification is not Doors Open During applied. Instead, Fuel Movement NUREG-1432 Rev. 1 is used. TSTF-207-A, Rev. 5 Completion Time for Not Not applicable to Restoration of Incorporated APR1400 since it has no Various Excessive secondary containment Leakage Rates and has no containment penetrations with more than two CIVs. Instead, NUREG-1432 Rev. 1 is used. TSTF-373-A, Rev. 2 Increase CIV Not Risk Informed Technical Completion Time in Incorporated Specification is not Accordance With applied. Instead, CE-NPSD-1168 NUREG-1432 Rev. 1 is used. TSTF-422-A, Rev. 2 Change in Technical Not Not applied because the Specifications End Incorporated APR1400 design-specific States analysis for modification of (CE-NPSD-1186) end state was not performed. Instead, NUREG-1432 Rev. 1 is used. KEPCO & KHNP 10

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Table II-5 APR1400 status of TSTFs that have been approved since NUREG-1432 Rev. 4 Approved TSTF Short Title Status for Technical Rationale Traveler APR1400 TSTF-425-A, Rev. 3 Relocate Not Risk Informed Technical Surveillance Incorporated Specification is not applied Frequencies to for APR1400 DCD. Licensee Control-RITSTF Initiative 5b TSTF-426-A, Rev. 5 Revise or Add Not Risk Informed Technical Actions to Preclude Incorporated Specification is not applied Entry into LCO 3.0.3 - for APR1400 DCD. RITSTF Initiatives 6b

                          & 6c TSTF-490-A, Rev. 0     Deletion of E Bar      Incorporated    In the APR1400, RCS Definition and                         specific activity Revision to RCS                        specification is revised in Specific ActivityTech                  accordance with Spec                                   TSTF-490-A, Rev. 0.

TSTF-505-A, Rev. 1 Provide Not Risk Informed Technical Risk-Informed Incorporated Specification is not applied Extended Completion for APR1400 DCD. Times - RITSTF Initiative 4b TSTF-510-A, Rev. 2 Revision to Steam Incorporated In the APR1400, SG Generator Program Program is revised in Inspection accordance with Frequencies and TSTF-510-A, Rev. 2. Tube Sample Selection TSTF-522-A, Rev. 0 Revise Ventilation Incorporated TSTF-522-A, Rev. 0 is System Surveillance applied to APR1400 Requirements to Technical Specifications. Operate for 10 hours per Month TSTF-523-A, Rev. 2 Generic Letter Incorporated TSTF-523-A (Managing 2008-01, Managing Gas Accumulation) is Gas Accumulation applied to APR1400 Technical Specifications. TSTF-529-A, Rev. 4 Clarify Use and Not Risk Informed Technical Application Rules Incorporated Specification is not applied for APR1400 DCD. KEPCO & KHNP 11

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Approved TSTF Short Title Status for Technical Rationale Traveler APR1400 TSTF-545-A, Rev. 3 TS Inservice Testing Not Not applied because this Program Removal & Incorporated change does not increase Clarify SR Usage operational safety. Rule Application to Section 5.5 Testing KEPCO & KHNP 12

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 III. SYSTEM LEVEL DEVIATIONS AND JUSTIFICATION STS are generally applicable to the APR1400 design. However, system level differences between STS and the APR1400 Technical Specifications exist to reflect design features that are different from the reference plant of NUREG-1432. In this section, the differences and technical justification of those systems are described. 1 Instrumentation 1.1 Major Design Features The reactor trip system (RTS) is a safety system which initiates reactor trips. The RTS consists of four channels of sensors, auxiliary process cabinet-safety (APC-S) cabinets, ex-core neutron flux monitoring system (ENFMS) cabinets, core protection calculator system (CPCS) cabinets, the reactor protection system (RPS) portion of plant protection system (PPS) cabinets, and reactor trip switchgear system (RTSS) cabinets. The RPS function is performed through measurement channels, bistable logics, RPS logics, and the reactor trip circuit breaker (RTCB). Measurement channels consist of the sensor and transmitter providing a process value to bistable logics. Bistable logics provide a trip signal to RPS logic comparing the process value with a predetermined setpoint. There are two bistable racks (including separate input and output modules, data links, one bistable processor, etc.) per channel. The RPS logic provides a trip signal to RTCB after performing 2/4 logic based on bistable trip status of four channels. There are two local coincidence logic racks (including separate input and output modules, data links, four local coincidence logic processors, etc.) per channel. The RTCB opens the trip switchgear based on a trip signal from RPS logic. The RTCB consists of undervoltage trip equipment and shunt trip equipment. The PPS interfaces with the undervoltage trip device of the RTCB. The diverse protection system (DPS) interfaces with the shunt trip device of the RTCB. The ESFAS function is performed through measurement channels, bistable logics, and ESFAS logics. Measurement channels consist of the sensor and transmitter providing a process value to bistable logics. Bistable logics provide a trip signal to ESFAS logic comparing the process value with a predetermined setpoint. There are two bistable racks (including separate input and output modules, data links, one bistable processor, etc.) per channel. The ESFAS logic consists of coincidence logic, initiation logic, and actuation logic. The four initiation logics in the PPS actuate a two-out-of-four logic in the ESF-CCS. In the actuation logic, each signal also sets a latch when the KEPCO & KHNP 13

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 two-out-of-four logic actuates to assure that the signal is not automatically reset once it has been initiated. 1.2 Major differences and justifications 1.2.1 In the APR1400, the Loss of Load RPS trip function is not used so the related contents are deleted. This deviation is related to APR1400 TS LCO 3.3.1. 1.2.2 In the APR1400, the Recirculation Actuation Signal, Containment Cooling Actuation Signal, and the Emergency Feedwater Actuation Signal ESFAS trip functions are not used so the related contents are deleted. The Auxiliary Feedwater Actuation Signal ESFAS trip function that considers only Steam Generator Level - Low is used instead of the Emergency Feedwater Actuation Signal. In addition, the Containment Cooling Actuation Signal ESFAS trip function is included in the Containment Spray Actuation Signal function. This deviation is related to APR1400 TS LCOs 3.3.5 and 3.3.6. 1.2.3 Logarithmic Power Level - High As described in DCD Tier 2, Table 7.2-1, Reactor Protection System Operating Bypass Permissive, the operating bypass permissive and removal setpoints for Logarithmic Power Level - High are 10-3 % RTP and < 10-3 % RTP, respectively. According to NUREG-1432 BASES SR 3.3.1.7, the CHANNEL FUNCTIONAL TEST (CFT) for the logarithmic power level channels is allowed to be performed 2 hours after reducing THERMAL POWER below 1E-4% RTP and is required to be performed only if the RTCBs are closed. This means that the CFT is not required until 2 hours after reducing THERMAL POWER below 1E-4% RTP or if the RTCBs are open. Therefore, the Note 2 of SR 3.3.1.7 has been changed to Not required to be performed for Logarithmic Power Level - High until 2 hours after reducing logarithmic power below 1E-3% and only if reactor trip circuit breakers (RTCBs) are open. This deviation is related to APR1400 TS LCO 3.3.1. 1.2.4 Pressurizer Pressure - Low The minimum setpoint for Pressurizer Pressure - Low is 100 psia as shown in DCD Tier 2, Table 7.2-4, Note (5). As described in DCD Tier 2, Table 7.2-1, Reactor Protection System Operating Bypass Permissive, the operating bypass permissive and removal setpoints for KEPCO & KHNP 14

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Pressurizer Pressure - Low are 400 psia and 500 psia, respectively. This deviation is related to APR1400 TS LCO 3.3.1. 1.2.5 Coincidence Logic APR1400 RPS has four Coincidence Logic channels instead of six Matrix Logic channels. This deviation is related to APR1400 TS LCOs 3.3.4 and 3.3.6. 1.2.6 Actuation Logic Some components cannot be tested during power operation since their actuation might lead to plant trip or equipment damage. Actuation Logic subgroups not tested during power operation must be tested in accordance with the Note of SR 3.3.6.2. Subgroup testing of each actuation logic channel A, C and B, D is performed on a STAGGERED TEST BASIS. The 31-day Frequency on a STAGGERED TEST BASIS is consistent with the operating experience of Korean NPPs. The APR1400 ESF-CCS does not have subgroup relays, but contains the logic for subgroup control. This deviation is related to APR1400 TS LCO 3.3.6. A channel is an arrangement of components and modules as required to generate a single protective action signal when required by a generating station condition. A channel loses its identity where single protective action signals are combined. Chapter 7 in DCD Tier 2, GTS and bases use the word "channel" or "division" for the portion of the circuit from the local coincidence logic to the actuation logic. The words "channel" and "division" are interchangeable regarding the portion from the local coincidence logic to the actuation logic. 1.2.7 Diverse Manual ESF Actuation Signal APR1400 instrumentation and control (I&C) systems provide Diverse Manual ESF Actuation controls and indications to provide protection against accidents and concurrent common cause failure of PPS and/or ESF-CCS. This deviation is related to APR1400 TS LCO 3.3.6. 1.2.8 Control Element Assembly Calculator (CEAC) In the APR1400 there are two CEACs in each CPCS channel. This change has come from the APR1400 CPCS configuration. In the CPCS configuration in STS, there had been two CEACs total, one at channel B and the other in channel C. In the APR1400 CPCS KEPCO & KHNP 15

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 configuration, there are two (2) CEACs in each channel and a total of eight (8) CEACs for the four channels. (See DCD Tier 2 Figure 7.2-4.) This deviation is related to APR1400 TS LCO 3.3.3. 2 Reactor Coolant System 2.1 Major Design Features The reactor coolant system (RCS) is a safety related system which removes the heat generated in the reactor core and transfers the heat to the steam generators. The reactor vessel, steam generators, reactor coolant pumps, pressurizer, and associated piping are the major components of the RCS. Two parallel heat transfer loops, each containing one steam generator and two reactor coolant pumps, are connected to the reactor vessel, and one pressurizer is connected to one of the hot legs. All RCS components are located inside the containment building. Overpressure protection for the reactor coolant pressure boundary is provided by four pilot operated safety relief valves (POSRVs) connected to the top of the pressurizer. These valves discharge to the in-containment refueling water storage tank (IRWST). 2.2 Major differences and justifications 2.2.1 In the APR1400, RCS specific activity specification is revised in accordance with TSTF-490, Rev. 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec as discussed in Section II.2.2. This deviation is related to APR1400 definitions and TS LCO 3.4.15. 2.2.2 Pressurizer Pilot Operated Safety Relief Valves (POSRVs) are used in the APR1400. The POSRV setpoint range for this valve type is different than the pressurizer safety valves in the STS. In the APR1400 TS LCO 3.4.10 APPLICABILITY section, the 72 hours exception is based on 18 hours of outage time for each of the four valves (APR1400 adapts 4 POSRVs). The 18-hour period is determined based on operating experience. This deviation is related to APR1400 TS LCO 3.4.10. KEPCO & KHNP 16

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 3 Emergency Core Cooling System 3.1 Major Design Features The SIS consists of four mechanically separated trains. Each train contains one SI pump and associated suction and discharge paths. The SI pumps take suction from the IRWST, which is located in the containment, and inject borated water into the RCS through DVI nozzles to flood and cool the core following a LOCA. The SIS is initiated automatically upon an SIAS or manually. The SIAS is produced by a two-out-of-four low pressurizer pressure or high containment pressure signal. The SIS is designed such that two diagonal SI pumps (i.e., SI pumps 1,3 or 2,4) in conjunction with the SITs provide 100 percent of the minimum injection flow rate to the core required to meet the system functions. The primary function of the SI pumps is to inject borated water into the RCS if a break occurs in the RCPB. For small break LOCA, the RCS pressure remains high for a long period following the accident, and the SI pumps provide reasonable assurance that the injected flow is sufficient to meet the criteria given in DCD Section 6.3.1. If necessary, SI pump flow is throttled to reduce RCS pressure to conditions that allow the initiation of shutdown cooling system operation. During shutdown cooling operations following a small break LOCA, the SI pumps continue injecting into the reactor vessel downcomer to provide makeup for spillage out the break. 3.2 Major differences and justifications 3.2.1 Safety injection tank (SITs) (LCO 3.5.1) In the APR1400, the SITs are available in MODE 4 with pressurizer pressure 50.3 kg/cm2A (715 psia) which is assumed in the Chapter 15 safety analysis. To implement the applicable range, the EOG and system design is changed. The detailed information is written in DCD Chapter 6.2 and APR1400-E-N-NR-14003-P, Rev. 0 (Section 4.3). 3.2.2 Safety Injection System (SIS) - Operating (LCO 3.5.2 and LCO 3.5.3) Safety analyses assume four SI trains operable in MODE 1, 2 and 3, but two SI trains OPERABLE in MODE 4, 5 and MODE 6 with vessel water level < 39.7 m (130 ft). Full flow from two diagonal SIS trains is credited because the safety analysis acceptance criteria cannot be satisfied should a cold leg break occur with the only two OPERABLE DVI nozzles being KEPCO & KHNP 17

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 adjacent to the faulted cold leg due to core bypass flow that could occur. Full flow from one SI pump and three SITs is used in safety analysis for a break in a DVI line. Therefore, four trains of SIS OPERABLE during MODES 1, 2 & 3 provides sufficient margin considering a failure of an EDG to start. NUREG-1432 Rev. 4 is based on ECCS consisting of two HPSIPs and two LPSIPs. APR1400 is based on ECCS consisting of four SIPs supported by four EDGs. Two trains located diagonally with respect to the reactor vessel or three trains are assumed OPERABLE in the safety analysis. For LCO 3.5.2 CONDITION B, two inoperable SI trains are allowable only if diagonally positioned in the reactor vessel. SI train #1 is diagonally positioned to SI train #3. SI train #2 is diagonally positioned to SI train #4. If the two inoperable injection lines are in a diagonal position in the reactor vessel, the two injection trains meet the flow requirements (100%) due to the small bypass through the break in the cold leg. The safety analysis assumes that at least two diagonally located SI trains are OPERABLE considering the bypass flow through the break. This deviation is related to APR1400 TS LCOs 3.5.2 and 3.5.3. 3.2.3 In-Containment Refueling Water Storage Tank (IRWST) (LCO 3.5.4)

   -    The IRWST is the water source of SIS during an accident and the applicable MODES for SIS are extended to the MODES specified in LCO 3.5.3. Therefore, the applicable MODES for the IRWST are extended for providing water to SIS.
   -    Both CONDITIONS A & C in NUREG-1432 are integrated into CONDITION A in APR1400.
   -    Both CONDITIONS B & E which have similar purpose are integrated into CONDITION C in the APR1400. There is no difference between NUREG-1432 and the APR1400 except for the extension of applicable MODES.
   -    IRWST water volume is used in the applicable safety analyses and the condition for IRWST volume is considered as an operability condition as specified in the BASES of CONDITION D in 3.5.4 of NUREG-1432. This is CONDITION B in APR1400.
   -    Due to the extension of the applicable MODES, a CONDITION for these MODES is added as CONDITION D.

KEPCO & KHNP 18

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3

   -    The REQUIRED ACTION of the APR1400 TS is a conservative approach. There is no difference between NUREG-1432 and the APR1400 because the REQUIRED ACTION B.1, E.1 AND E.2 for CONDITION A and C or D in NUREG-1432 are integrated into the CONDITION A or C not met for the APR1400.
   -    Due to the extension of the applicable MODES, REQUIRED ACTIONS for the MODES are added.
   -    The NOTE is not necessary for APR1400 since the IRWST is located in reactor containment building and is not affected by changing of the ambient air temperature.
   -    Due to the integrations of the CONDITIONS, related REQUIRED ACTIONS and COMPLETION TIMES are changed.

KEPCO & KHNP 19

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 4 Electrical power systems 4.1 Major Design Features 4.1.1 AC Electric Power Distribution System The AC electric power distribution system consists of the transmission system, the plant switchyard, main transformer (MT), two unit auxiliary transformers (UATs), two standby auxiliary transformers (SATs), a main generator (MG), a generator circuit breaker (GCB), isolated phase bus, switchgears, load centers (LCs), and motor control centers (MCCs). The electric power distribution system also includes the power, control, instrumentation cables and raceways, and electrical protection devices, such as circuit breakers and fuses. The Class 1E AC electric power distribution system consists of two independent, redundant divisions. Each division consists of two independent trains. Four emergency diesel generators (EDGs) provide Class 1E power to the four independent Class 1E trains respectively, during a LOOP or a LOOP concurrent with a DBA. One AC generator provides power to the permanent non-safety buses during a LOOP or to one Class 1E train during a SBO. During plant normal operation, the MG supplies power through the GCB and MT to the transmission system, and to the UATs. When the GCB is open, power is backed from the transmission system through the MT to the UATs. In the event of a loss of preferred power supply through the UATs, medium voltage (non-Class 1E 13.8 kV and Class 1E & non-Class 1E 4.16 kV) buses are powered from the SATs after performing an automatic bus transfer from the normal offsite preferred power supply to the alternate offsite preferred power supply. 4.1.2 DC Power System The Class 1E 125 Vdc system consists of four independent subsystems, trains A, B, C, and D, each corresponding to one of the four reactor protection instrumentation channels A, B, C, and D. The non-Class 1E DC power system is also comprised of two separate subsystems, divisions I and II. Each Class 1E and non-Class 1E DC power system is provided with its own battery, two battery chargers (normal and standby), a DC control center, and DC distribution panels. The Class 1E DC KEPCO & KHNP 20

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 power system supplies reliable continuous power to the plant safety system DC loads and the Class 1E I&C system. 4.1.3 Instrumentation and Control Power System The instrumentation and control (I&C) power system consists of Class 1E and non-Class 1E power systems. The Class 1E 120 Vac I&C power system is separated into four subsystems, trains A, B, C, and D that supply power to the plant protection system channels A, B, C, and D. The Class 1E I&C power system includes four separate and independent 120 Vac power distribution panel, and each system is powered from a 125 Vdc control center via a 125 Vdc/120 Vac static inverter. 4.2 Major differences and justifications 4.2.1 The APR1400 adopts four EDGs (two redundant and independent divisions I and II, but four independent trains A, B, C, and D). Each division of EDGs provides Class 1E power to its respective Class 1E redundant loads. For each EDG, one automatic load sequencer is provided. The unavailability of either one or two EDGs on one division disables one load group to perform its partial or all of the safety functions. Because of the divisional approach of the four EDGs in the APR1400 design, the condition with three or more AC sources inoperable is divided into two different cases. This deviation is related to APR1400 TS LCOs 3.8.1 and 3.8.2. 4.2.2 The term "Train A" and Train B used in NUREG-1432 is replaced by "Division I" and Division II in APR1400. Between divisions, independence and redundancy are maintained. For DC systems, the term subsystem(s) used in NUREG-1432 is replaced by Division(s) in APR1400. This deviation is related to APR1400 TS LCOs 3.8.1, 3.8.2, 3.8.4, 3.8.5, 3.8.6, 3.8.7 and 3.8.9. KEPCO & KHNP 21

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 These changes are not included in Table III-1. 4.2.3 For the following LCOs and SRs, the specific values of the STS enclosed in brackets are changed to APR1400 design values.

       - SR 3.8.1.4, 3.8.1.7, 3.8.1.11, 3.8.1.12, 3.8.1.15, 3.8.1.19, 3.8.1.20, 3.8.3.4 and 3.8.4.2
       - LCO 3.8.3 5        Refueling Operation 5.1      Major Design Features The shutdown cooling system (SCS) is a safety-related system that is used to reduce the temperature of the reactor coolant system (RCS) in post shutdown periods from the hot shutdown operating temperature to the refueling temperature. The initial phase of a cooldown is accomplished by heat rejection from the steam generators (SGs) to the condenser or atmosphere.

After the reactor coolant temperature and pressure have been reduced to approximately 176.7°C (350°F) and 31.6 kg/cm2A (450 psia), the SCS is put into operation for normal shutdown cooling to reduce the RCS temperature to the refueling temperature, and to maintain this temperature during refueling. Additionally, the SCS is used in conjunction with the main steam atmospheric dump valves (MSADVs) and the auxiliary feedwater system to cooldown the RCS following a small break loss of coolant accident (LOCA). The SCS is also used subsequent to steam and feedwater line breaks, steam generator tube ruptures, and is used during plant startup prior to RCP restart to maintain flow through the core. After an accident, the SCS can be put into operation when the RCS temperature and pressure are below approximately 193.3°C (380°F) and 28.1 kg/cm2A (400 psia), respectively. The plant refueling cavity is equipped with devices that monitor the level of the refueling water in the refueling cavity. If the monitoring devices detect an inappropriate decrease in the level of refueling water during the refueling operation, the operator in the main control room (MCR) is alerted, and the operator takes immediate action to prevent water leakage. KEPCO & KHNP 22

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 5.2 Major differences and justifications 5.2.1 RCS Loops - MODE 5 A CSP can be realigned to be used as a Shutdown Cooling Pump (SCP) because the SCPs and CSPs are interchangeable. This deviation is related to APR1400 TS LCOs 3.4.7 and 3.4.8. 5.2.2 Low Temperature Overpressure Protection (LTOP) System (LCO 3.4.11)

   -    SCS suction isolation valves are sized to accommodate mass addition from four SIPs and one charging pump. The flow rates from two charging pumps during pump switchover are limited by flow restrictors. Therefore, there is no need to limit charging pump operation.
   -    SIT operating pressure is 610 psig and SIT discharge cannot pressurize the RCS higher than the LTOP limit pressure of 625 psia because RCS pressure can be assumed to be less than 450 psia (SCS cut in pressure), and RCS volume is larger than SIT. Therefore, there is no need to include SIT isolation in the APR1400 Technical Specifications.
   -    Relief valves for LTOP function are used in APR1400 instead of PORVs. These relief valves have full capacity each and are considered a passive device. A risk assessment for passive relief valves is not required. Therefore, the NOTE for 3.0.4.b is deleted.

5.2.3 Shutdown Cooling (SDC) and Coolant Circulation - Low Water Level (LCO 3.9.5) CSP can be realigned to be used as SCP because SCP and CSP are interchangeable. CSP operability during reduced inventory operation is required. 5.2.4 Refueling Water Level (LCO 3.9.6) The recently irradiated fuel assemblies in NUREG-1432 are included in the irradiated fuel assemblies described in APR1400. The REQUIRED ACTION is added to exit the LCO condition. KEPCO & KHNP 23

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 6 Containment System 6.1 Major Design Features The CS System (CSS) reduces containment pressure and temperature and removes fission products from the containment atmosphere following a DBA, and has two independent divisions including two containment spray (CS) pumps, two CS heat exchangers, two CS mini-flow heat exchangers, two independent spray headers, associated piping, valves, and instrumentation. The spray flow is provided by the CSPs, which start on the receipt of a safety injection actuation signal (SIAS) or containment spray actuation signal (CSAS), and take suction from the IRWST. The CSPs discharge through the CSHXs and the spray header isolation valves to their respective spray nozzle headers and then into the containment atmosphere. Spray flow to the CS nozzle headers is not provided until a CSAS automatically opens the containment spray header isolation valves. 6.2 Major differences and justifications 6.2.1 Containment Spray and Cooling System (LCO 3.6.6) In APR1400, a 72 hour Completion Time applies for one containment spray division inoperable instead of the 7 day Completion Time in NUREG-1432, because APR1400 does not adopt CE NPSD-1045-A and does not meet the requirements of the Topical Report and the associated Safety Evaluation. 6.2.2 Spray Additive System (LCO 3.6.7) Since post-accident pH control of the sprayed fluid is provided using trisodium phosphate (TSP), which is stored in the holdup volume tank (HVT), the Spray Additive System is not applied to APR1400. 6.2.3 Hydrogen Mixing System (HMS) (LCO 3.6.9) Since hydrogen mixing is accomplished by the Containment Spray System, the Hydrogen Mixing System is not applied to APR1400. KEPCO & KHNP 24

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 6.2.4 Iodine Cleanup System (ICS) (LCO 3.6.10) The removal of fission products (e.g. iodine) is accomplished by the Containment Spray System. Therefore, the Iodine Cleanup System is not applied to APR1400. 7 Plant System 7.1 Major Design Features 7.1.1 Component Cooling Water System The Component Cooling Water System (CCWS) consists of two safety-related divisions that are separate, independent, redundant, and closed-loop. Either division of the CCWS is capable of supporting 100 percent of the cooling requirements of a safe shutdown following a postulated accident coincident with LOOP. Each CCWS division includes three CCW heat exchangers, a CCW surge tank, two CCW pumps, a CCW chemical addition tank, and CCW radiation monitor, piping, valves, controls, and instrumentations. The CCWS provides cooling water to the essential (safety Class 3) and nonessential (non-nuclear safety class) components. 7.1.2 Essential Service Water System The Essential Service Water System (ESWS) consists of two independent, redundant, once-through, safety-related divisions. Each division of the ESWS consists of two pumps, three debris filters, and associated piping, valves, controls, and instrumentations. The ESW pumps take suction from the ultimate heat sink (UHS) basin, circulate cooling water through the CCW heat exchangers, and return cooling water back to the UHS. 7.1.3 Ultimate Heat Sink (UHS) The function of the UHS is to dissipate the heat rejected from the ESWS during all MODES of operation including accident conditions. The UHS is a site-specific system that interfaces with the ESWS. Based on the conceptual design, the UHS consists of two independent, redundant, safety-related divisions. Each division consists of two 100 percent capacity UHS cooling towers, one common UHS cooling tower basin, piping, valves, controls and instrumentation. KEPCO & KHNP 25

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 7.1.4 Spent Fuel Pool The Spent Fuel Pool (SFP) is approximately 7.31 m (42 ft) deep and made of reinforced concrete lined with stainless steel plate. The SFP is sufficiently deep that when a spent fuel assembly is being carried over the spent fuel storage racks by the spent fuel handling machine (SFHM) at its maximum lift height, there is sufficient water coverage to provide reasonable assurance that personnel on the SFHM or on the operating floor around the pool are not exposed to radiation levels exceeding 0.025 mSv (0.0025 rem) per hour. Two safety-related SFP water level transmitters are installed in the SFP to measure the SFP water level from a 100 percent water level to the top level of the spent fuel assemblies. The SFP water level transmitters annunciate high water level, low water level, and low-low water level of the SFP to the MCR, RSR, and locally. The SFP is initially filled with water that has a boron concentration range of 4,000 to 4,400 ppm. The SFP receives normal borated makeup water from the boric acid storage tank (BAST) or from the boric acid makeup pump (BAMP). The SFP boron concentration is checked at local sample points. Local sample connections are provided in the spent fuel pool cooling and cleanup system (SFPCCS) purification return line to check the effectiveness of the filter and the demineralizer or one of them, as well as the boron concentration. 7.2 Major differences and justifications 7.2.1 Ultimate Heat Sink (UHS) (LCO 3.7.9) Based on the conceptual design, the APR1400 UHS consists of two independent, redundant, safety-related divisions. Each division consists of two 100 percent capacity cooling towers. CONDITION B of APR1400 is described comprehensively to include CONDITION B, C, and D of NUREG-1432. KEPCO & KHNP 26

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Table III-1 Deviations and Justification between Standard Technical Specifications and the APR1400 Technical Specifications Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 1.0 USE AND APPLICATION 1.1 Definitions None CORE ALTERATION See II.2.1 DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 See II.2.2 Modified

                         -AVERAGE DISINTEGRATION            DOSE EQUIVALENT XE-133              See II.2.2 ENERGY CHANNEL CALIBRATION                 CHANNEL CALIBRATION A CHANNEL CALIBRATION shall         A CHANNEL CALIBRATION shall be the adjustment, as necessary,    be the adjustment, as necessary, of the channel output such that it  of the channel output such that it responds within the necessary       responds within the necessary range and accuracy to known         range and accuracy to known values of the parameter that the    values of the parameter that the channel monitors. The CHANNEL       channel monitors. The CHANNEL CALIBRATION shall encompass all     CALIBRATION shall encompass devices in the channel required for the entire channel, including the channel OPERABILITY and the         required sensor, alarm, and trip CHANNEL FUNCTIONAL TEST.            functions, and shall include the Calibration of instrument channels  CHANNEL FUNCTIONAL TEST.

with resistance temperature Calibration of instrument channels detector (RTD) or thermocouple with resistance temperature sensors may consist of an inplace detector (RTD) or thermocouple qualitative assessment of sensor sensors may consist of an in-place behavior and normal calibration of cross calibration of the sensing the remaining adjustable devices in elements and normal calibration of the channel. The CHANNEL the remaining adjustable devices in CALIBRATION may be performed the channel. Whenever a sensing by means of any series of element is replaced, the next sequential, overlapping, or total required in-place cross calibration channel steps. consists of comparing the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series KEPCO & KHNP 27

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) of sequential, overlapping, or total channel steps so that the entire channel is calibrated. CHANNEL FUNCTIONAL TEST CHANNEL FUNCTIONAL TEST

a. Analog and bistable channels - a. Analog and bistable logic the injection of a simulated or channels - the injection of a actual signal into the channel as simulated or actual signal into close to the sensor as the channel as close to the practicable to verify sensor as practicable to verify OPERABILITY of all devices in OPERABILITY, including the channel required for channel required alarms, interlocks, OPERABILITY, and display and trip functions.
b. Digital computer channels - the b. Digital computer channels - the use of diagnostic programs to use of diagnostic programs to test digital computer hardware test digital computer hardware and the injection of simulated and the injection of simulated process data into the channel to process data into the channel to verify OPERABILITY of all verify OPERABILITY, including devices in the channel required alarms and trip functions.

for channel OPERABILITY. The CHANNEL FUNCTIONAL The CHANNEL FUNCTIONAL TEST may be performed by means TEST may be performed by means of any series of sequential, of any series of sequential, overlapping, or total channel steps. overlapping, or total channel steps so that the entire channel is tested. ENGINEERED SAFETY ENGINEERED SAFETY FEATURE (ESF) RESPONSE FEATURE (ESF) RESPONSE TIME TIME The ESF RESPONSE TIME shall The ESF RESPONSE TIME shall be that time interval from when the be the time interval from when the monitored parameter exceeds its monitored parameter exceeds its ESF actuation setpoint at the ESF actuation setpoint at the channel sensor until the ESF channel sensor until the ESF equipment is capable of performing equipment is capable of performing its safety function (i.e., the valves its safety function (i.e., the valves travel to their required positions, travel to their required positions, KEPCO & KHNP 28

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) pump discharge pressures reach pump discharge pressures reach their required values, etc.). Times their required values, etc.). Times shall include diesel generator shall include emergency diesel starting and sequence loading generator starting and sequence delays, where applicable. The loading delays, where applicable. response time may be measured The response time may be by means of any series of measured by means of any series sequential, overlapping, or total of sequential, overlapping, or total steps so that the entire response steps so that the entire response time is measured. In lieu of time is measured. In lieu of measurement, response time may measurement, response time may be verified for selected be verified for selected components provided that the components provided that the components and methodology for components and methodology for verification have been previously verification have been previously reviewed and approved by the reviewed and approved by the NRC. NRC. MODE MODE Changed from A MODE shall correspond to any A MODE shall correspond to any average reactor one inclusive combination of core one inclusive combination of core coolant reactivity condition, power level, reactivity condition, power level, temperature to average reactor coolant reactor coolant cold leg reactor coolant temperature, and reactor vessel temperature, and reactor vessel cold leg head closure bolt tensioning head closure bolt tensioning temperature specified in Table 1.1-1 with fuel in specified in Table 1.1-1 with fuel in the reactor vessel. reactor vessel. KEPCO & KHNP 29

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) OPERABLE - OPERABILITY OPERABLE - OPERABILITY See II.2.3 Response to RAI A system, subsystem, train, A system, subsystem, division, No. 130-8065 component, or device shall be train, component or device shall be Question 16-30 OPERABLE or have OPERABLE or have (Revision 1) OPERABILITY when it is capable OPERABILITY when it is capable committed to add to of performing its specified safety of performing its specified safety deviation report function(s) and when all necessary function(s) and when all necessary and to provide attendant instrumentation, controls, attendant instrumentation, controls, further explanation. normal or emergency electrical normal or emergency electrical power, cooling and seal water, power, cooling and seal water, lubrication, and other auxiliary lubrication, and other auxiliary equipment that are required for the equipment that are required for the system, subsystem, train, system, subsystem, division, train, component, or device to perform its specified safety function(s) are also component, or device to perform its capable of performing their related specified function(s) are also support function(s). capable of performing their related support function(s). KEPCO & KHNP 30

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REACTOR PROTECTION REACTOR PROTECTION APR1400 has no methodology SYSTEM (RPS) RESPONSE TIME SYSTEM (RPS) RESPONSE TIME for response time verification The RPS RESPONSE TIME shall The RPS RESPONSE TIME shall without measurement. be that time interval from when the be that time interval from when the monitored parameter exceeds its monitored parameter exceeds its RPS trip setpoint at the channel RPS trip setpoint at the input to the sensor until electrical power to the channel sensor until electrical CEAs drive mechanism is power to the CEAs drive interrupted. The response time mechanism is interrupted. The may be measured by means of any response time may be measured series of sequential, overlapping, by means of any series of or total steps so that the entire sequential, overlapping, or total response time is measured. In lieu steps so the entire response time is of measurement, response time measured. In lieu of measurement, may be verified for selected response time may be verified for components provided that the selected components provided that components and methodology for the components and methodology verification have been previously for verification have been reviewed and approved by the previously reviewed and approved NRC. by the NRC. Table 1.1-1 Table 1.1-1 AVERAGE REACTOR COOLANT REACTOR COOLANT COLD LEG See II.3.1 TEMPERATURE (°F) TEMPERATURES

                         > [200]                              > 99°C (210°F)
                         > [200]                               99°C (210°F) 1.2 Logical Connectors                      -                 Same as NUREG-1432 1.3 Completion Times                        -                 Same as NUREG-1432 1.4 Frequency                               -                 Same as NUREG-1432 2.0 SAFETY LIMITS 2.1 SLs                  2.1.1.1 In MODES 1 and 2,            2.1.1.1 In MODES 1 and 2, departure from nucleate              departure from nucleate KEPCO & KHNP                                                                                                                                       31

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) boiling ratio (DNBR) shall boiling ratio (DNBR) shall be maintained at [1.19]. be maintained 1.29. 2.1.1.2 In MODES 1 and 2, the 2.1.1.2 In MODES 1 and 2 the peak Ref. CENPD-382-P-A is related peak fuel centerline fuel centerline temperature to Erbium BA. Only Gd BA is temperature shall be shall be maintained at considered in APR1400. maintained at < [5080]°F, < 2,804.4°C (5,080°F), decreasing by [58°F per decreasing by 32.2°C 10,000 MWD/MTU] and (58°F) per 10,000 adjusted for burnable MWD/MTU for burnup and poison per [CENPD-275-P, adjusted for burnable Revision 1-P-A or poison per CENPD-275-P, CENPD-382-P-A]. Revision 1-P-A. 2.2 SL Violations - Same as NUREG-1432 3.0 LIMITING CONDITIONS FOR OPERATION APPLICABILITY LCO 3.0.1 - Same as NUREG-1432 LCO 3.0.2 - Same as NUREG-1432 LCO 3.0.3 - Same as NUREG-1432 LCO 3.0.4 When an LCO is not met, entry into When an LCO is not met, entry into LCO 3.0.4 is based on a MODE or other specified a MODE or other specified NUREG-1432, Revision 1 condition in the Applicability shall Condition in the Applicability shall (Second paragraph, third only be made: not be made except when the sentence) and also on

a. When the associated ACTIONS associated ACTIONS to be entered Revision 2. Since risk informed to be entered permit continued permit continued operation in the TS are not applied to APR1400 operation in the MODE or other MODE or other specified Condition generic TS, the non-risk specified condition in the in the Applicability for an unlimited informed last paragraph, which Applicability for an unlimited period of time. was removed by TSTF-359-A, period of time; Revision 9 (which was
b. After performance of a risk This Specification shall not prevent incorporated in CE-STS assessment addressing changes in MODES or other Revision 3), is retained.

inoperable systems and specified conditions in the components, consideration of Applicability that are required to the results, determination of the comply with ACTIONS or that are acceptability of entering the part of a shutdown of the unit. MODE or other specified Exceptions to this Specification are KEPCO & KHNP 32

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) condition in the Applicability, stated in the individual and establishment of risk Specifications. These exceptions management actions, if allow entry into MODES or other appropriate; exceptions to this specified Conditions in the Specification are stated in the Applicability when the associated individual Specifications, or ACTIONS to be entered allow unit

c. When an allowance is stated in operation in the MODE or other the individual value, parameter, specified condition in the or other Specification. Applicability only for a limited period of time.

This Specification shall not prevent changes in MODES or other LCO 3.0.4 is only applicable for specified conditions in the entry into a MODE or other Applicability that are required to specified Condition in the comply with ACTIONS or that are Applicability in MODES 1, 2, 3, part of a shutdown of the unit. and 4. LCO 3.0.5 - Same as NUREG-1432 LCO 3.0.6 - Same as NUREG-1432 LCO 3.0.7 - Same as NUREG-1432 LCO 3.0.8 - Same as NUREG-1432 LCO 3.0.9 - Same as NUREG-1432 3.0 SURVEILLANCE REQUIREMENT APPLICABILITY SR 3.0.1 - Same as NUREG-1432 SR 3.0.2 - Same as NUREG-1432 SR 3.0.3 If it is discovered that a If it is discovered that a Surveillance was not performed Surveillance was not performed within its specified Frequency, then within its specified Frequency, then compliance with the requirement to compliance with the requirement to declare the LCO not met may be declare the LCO not met may be delayed, from the time of delayed, from the time of discovery, discovery, up to 24 hours or up to up to 24 hours or up to the limit of the limit of the specified Frequency, the specified Frequency, whichever whichever is greater. This delay is less. This delay period is KEPCO & KHNP 33

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) period is permitted to allow permitted to allow performance of performance of the Surveillance. the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed. SR 3.0.4 None Entry into a MODE or other SR 3.0.4 is based on specified Condition in the NUREG-1432, Revision 2. Since Applicability of an LCO shall only risk informed TS are not applied be made when the LCOs to APR1400 generic TS, the Surveillances have been met within non-risk informed last paragraph, their specified Frequencies except which was removed by as provided by SR 3.0.3. When an TSTF-359-A, Revision 9, is LCO is not met due to retained. Surveillances not having been met, entry into a MODE or other specified Condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified Conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. SR 3.0.4 is only applicable for entry into a MODE or other specified Condition in the Applicability in MODES 1, 2, 3, and 4. 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN LCO 3.1.1 LCO 3.1.1 The SDM specifications Related MARGIN (SDM) SDM shall be within the limits a. SDM shall be within the limits according to RTCB condition CONDITION (with specified in the COLR. specified in the COLR. reflect the assumptions of the associated KEPCO & KHNP 34

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) safety analyses. REQUIRED

b. k effective assuming the The function of kN-1 is to maintain ACTION and inserted control element sufficient subcriticality to COMPLETION assembly (CEA) of the highest preclude inadvertent criticality TIME) and related worth is fully withdrawn (kN-1) following ejection of a single SURVEILLANCE shall be < 0.99. control element assembly. (and FREQUENCY)

The requirement prohibiting are added.

c. With reactor trip circuit breakers criticality due to shutdown group (RTCBs) closed: Reactor CEA movement is associated criticality shall not be achieved with the assumptions used in the with shutdown group CEAs analysis of uncontrolled CEA movement. withdrawal from subcritical condition. Due to the high differential reactivity worth of the shutdown CEA groups, the analysis assumes that the initial shutdown reactivity is such that the reactor will remain subcritical in the event of unexpected or uncontrolled shutdown group withdrawal.

3.1.2 Reactivity Balance REQUIRED ACTION A.2 REQUIRED ACTION A.2 Establish appropriate Establish appropriate operating operating restrictions and restrictions and SRs for continued SRs. operation. KEPCO & KHNP 35

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.1.3 Moderator LCO 3.1.3 LCO 3.1.3 See II.4 Temperature The MTC shall be maintained The MTC shall be maintained The actual value of the MTC is Coefficient (MTC) within the limits specified in the within the lower limit specified in dependent on core COLR, and a maximum positive the COLR and the upper limit that characteristics such as fuel limit as specified below: varies linearly from 0.9E-4 k/k/°C loading and reactor coolant (0.5E-4 k/k/°F) at 0% RTP to soluble boron concentrations.

a. [0.5 E-4 k/k/°F] when 0.0 k/k/°C (0.0 k/k/°F) at 100% Since positive MTC limits THERMAL POWER is 70% RTP. assumed in the safety analysis RTP and are not to be challenged or must be met using burnable absorbers
b. [0.0 k/k/°F] when THERMAL for both initial and the reload POWER is > 70% RTP. cores, thus, those are not classified as COLR item in APR1400.

SURVEILLANCE SURVEILLANCE See II.4 SR 3.1.3.1 Verify MTC is within the SR 3.1.3.1 Verify MTC is within the upper limit specified in the upper limit specified in LCO 3.1.3. COLR. SR 3.1.3.2 SR 3.1.3.2

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

If the MTC is more negative than If the MTC is more negative than the limit specified in the COLR the COLR limit when extrapolated when extrapolated to the end of to the end of cycle, SR 3.1.3.2 may cycle, SR 3.1.3.2 may be repeated. be repeated. Shutdown must occur Shutdown must occur prior to prior to exceeding the minimum exceeding the minimum allowable allowable boron concentration at boron concentration at which MTC which MTC is projected to exceed is projected to exceed the lower the lower limit. limit. ------------------------------------------

                         ------------------------------------------       Verify MTC is within the lower Verify MTC is within the lower            limit specified in the COLR.

limit specified in the COLR. 3.1.4 Control Element SURVEILLANCE SURVEILLANCE This SR confirms the required Assembly SR 3.1.4.5 SR 3.1.4.5 CEA drop time assumed in the KEPCO & KHNP 36

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Alignment (CEA) Verify each full length CEA drop Verify each full strength CEA drop safety analysis. This CEA drop time [3.5] seconds and the time from the fully withdrawn time is in Figure 4.2-14 of DCD arithmetic average of all full length position to the 90% insertion Tier 2. CEA drop times [3.2] seconds. position is 4 seconds. Figure 3.1.4-1 Figure 3.1.4-1

                         -----------------NOTE-----------------     -----------------NOTE-----------------     Each power plant has a different When core power is reduced to              When core power is reduced to              core power level which requires 60% RTP per this limit curve,              55% RTP per this limit curve,              no further reduction with respect further reduction is not required by       further reduction is not required by       to CEA deviation. The power this Specification.                        this Specification.                        level depends upon which power
                         ------------------------------------------ ------------------------------------------ level that is secured as the initial thermal margin to compensate for the thermal margin decrement caused by the long-term xenon redistribution after the operators intervention to counteract the CEA deviation.

For the case of the APR1400 plant, when core power is below 55% RTP, initial thermal margin can encompass the thermal margin decrement by xenon redistribution after the CEA deviation. Further power reduction is not required when core power is reduced to 55% RTP. 3.1.5 Shutdown Control FREQUENCY FREQUENCY A FREQUENCY is added to Element Assembly SR 3.1.5.1 SR 3.1.5.1 ensure that required SDM is (CEA) Insertion 12 hours 12 hours maintained by verifying each Limits shutdown CEA is withdrawn AND greater than or equal to 367.7 cm (144.75 in) (SR 3.1.5.1) Once within 15 minutes prior to within 15 minutes prior to withdrawal of any CEAs in withdrawal of any CEA in KEPCO & KHNP 37

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) regulating groups during an regulating groups during an approach to reactor criticality. approach to reactor criticality. 3.1.6 Regulating Control LCO 3.1.6 LCO 3.1.6 Element Assembly b. With COLSS out of service, the b. With COLSS out of service, the The withdrawal sequence should (CEA) Insertion regulating CEA groups shall be regulating CEA groups shall be be maintained with COLSS out Limits limited to the short term steady limited to the withdrawal of service, as well as with state insertion limit and sequence, insertion limits, and COLSS in service. associated time restraints associated time restraints specified in the COLR. specified in the COLR. SURVEILLANCE SURVEILLANCE The NOTE in APR1400 GTS SR SR 3.1.6.1 SR 3.1.6.1 3.1.6.1 is equivalent to CE-STS

                         -----------------NOTE-----------------     -----------------NOTE-----------------     SR 3.1.6.1 NOTE because the Not required to be performed until         Not required to be performed prior         interval for Frequency (12 hours) 12 hours after entry into MODE 2.          to entry into MODE 2.                      is same as the allowed time after
                         ------------------------------------------ ------------------------------------------ entry into MODE 2 in STS.

Therefore, there is no deviation from the STS. 3.1.7 Part Length CONDITION CONDITION The CONDITION is not needed Control Element A. Part length CEA groups inserted None for APR1400 since the transient Assembly (CEA) beyond the transient insertion limit. insertion of part strength CEAs is Insertion Limits not restricted up to the full insertion in APR1400. B. Part length CEA groups inserted A. Part strength CEA groups APR1400 GTS corrected between the long term steady state inserted between the long term inaccurate expression intervals insertion limit and the transient steady state insertion limit and the in STS with accumulated times insertion limit for intervals 7 transient insertion limit for and added interval after 30 ettective full power days (EFPD) accumulated times > 7 ettective full EFPD for clarification and per 30 EFPD or 14 EFPD per 365 power days (EFPD) per 30 EFPD accuracy. EFPD interval. interval or > 14 EFPD per 365 Greater than or equal to EFPD interval. symbols () in STS are typos and are replaced with greater than symbols (>) in GTS. KEPCO & KHNP 38

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE The surveillance requirement for Related None SR 3.1.7.2 the verification of the FREQUENCY is Verify the accumulated times accumulated time beyond the added. during which the part strength CEA long term steady state insertion groups are inserted beyond the limits is added to be consistent long term steady state insertion with CONDITION A of ACTIONS. limit. Addition None LCO 3.1.8 Charging flow restriction during Related ACTIONS

 - Charging Flow                                         Charging flow shall be maintained  MODES 1,2,3,4 and 5 is an              and below 681.4 L/min (180 gpm).       assumption of initial condition for    SURVEILLANCE safety analysis as described in        REQUIREMENTS APPLICABILITY                                                             are added.

the APR1400 DCD Tier 2, MODES 1, 2, 3, 4, and 5. Section 15.4.6. 3.1.8 Special Test LCO 3.1.8 LCO 3.1.9 RPS bypass setpoint change Exceptions (STE) During performance of PHYSICS During performance of criticality was determined as a STE during

      - SHUTDOWN         TESTS, the requirements of:     test or measurement of control     a previous plant startup test.

MARGIN (SDM) element assembly (CEA) worth and RPS bypass setpoint changes SDM, the requirements of: need to prevent unnecessary reactor trip by RPS during criticality test. The criticality test and related SR are added. None LCO 3.3.1, Reactor Protection The STE for LCO 3.3.1 for RPS System (RPS) Instrumentation - Instrumentation is added. Operating (Only applied to Trip Functions 2, 14, and 15 in Table 3.3.1-1), and None LCO 3.3.2, Reactor Protection The STE for LCO 3.3.2 for RPS System (RPS) Instrumentation - Instrumentation is added. Shutdown (Only applied to Trip Function 1 in Table 3.3.2-1), KEPCO & KHNP 39

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) may be suspended for may be suspended, provided The last sentence after or is measurement of CEA worth, shutdown reactivity equivalent to at added due to criticality test and provided shutdown reactivity least the highest estimated CEA dynamic rod worth equivalent to at least the highest worth (of those CEAs actually measurement. estimated CEA worth (of those withdrawn) is available for trip CEAs actually withdrawn) is insertion or the reactor is subcritical available for trip insertion. by at least the reactivity equivalent of the highest CEA worth. SURVEILLANCE SURVEILLANCE SR 3.1.9.3 is added due to the None SR 3.1.9.3 criticality test.

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

Applicable to operation in MODE 3 only. Verify that when all full strength CEAs are fully inserted, the reactor is subcritical by more than the above required shutdown reactivity equivalent. None SR 3.1.9.4 SR 3.1.9.4 is added due to the Perform CHANNEL FUNCTIONAL application of STE for RPS TESTS of each logarithmic and Instrumentation LCO 3.3.1 and variable overpower neutron flux 3.3.2. monitoring channel. 3.1.9 Special Test LCO 3.1.9 LCO 3.1.10 The STE for LCO 3.2.5 of ASI is Exceptions (STE) None LCO 3.2.5, AXIAL SHAPE INDEX added for initial startup test.

      - MODES 1 and 2                                        (ASI),                                     (ex. CPC power distribution test)

(Digital) Addition None LCO 3.1.11 The STE for LCO 3.1.7 and LCO Related ACTIONS

 - Special Test                                              During performance of PHYSICS               3.1.8 are added for initial core   and Exception (STE) -                                         TESTS, the requirements of:                 startup test.                      SURVEILLANCE Reactivity Coefficient                                    LCO 3.1.6, Regulating Control                                                 REQUIREMENTS Testing                                                           Element Assembly (CEA)                                                 are added.

Insertion Limits, The LCO for cold leg LCO 3.1.7, Part Strength CEA temperature is narrow for KEPCO & KHNP 40

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Insertion Limits, and APR1400, so the LCO 3.4.1.b LCO 3.4.1, RCS Pressure, may be suspended. Temperature and Flow limits (LCOs 3.4.1.b and 3.4.1.c, RCS Cold Leg Temperature only), may be suspended, provided Linear Heat Rate (LHR) and Departure from Nucleate Boiling Ratio (DNBR) do not exceed the limits specified in: LCO 3.2.1, Linear Heat Rate (LHR), and LCO 3.2.4, Departure from Nucleate Boiling Ratio (DNBR). APPLICABILITY MODE 1 with THERMAL POWER

                                                         > 20% RTP.

ACTIONS CONDITION A. LHR or DNBR not within limits. B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Reduce THERMAL POWER to restore LHR and DNBR to within limits. B.1 Suspend PHYSICS TESTS. COMPLETION TIME KEPCO & KHNP 41

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 15 minutes 1 hour SURVEILLANCE SR 3.1.11.1

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

Only required to be performed when Core Operating Limits Supervisory System (COLSS) is out of service. With COLSS in service, LHR is continuously monitored. Verify LHR, as indicated on any OPERABLE Core Protection Calculator local power density channel, is within the limit specified in the COLR. SR 3.1.11.2

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

Only required to be performed when COLSS is out of service. With COLSS in service, DNBR is continuously monitored. Verify DNBR, as indicated on any OPERABLE Core Protection Calculator DNBR channel, is within the limits of Figure 3.2.4-2 or Figure 3.2.4-3 of the COLR, as applicable. FREQUENCY 15 minutes 15 minutes KEPCO & KHNP 42

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Addition None LCO 3.1.12

 - Unborated Water                                       The CV-186 valve used to isolate Source Isolation                                      unborated water sources shall be Valve - MODES 4                                       secured in the closed position.

and 5 APPLICABILITY MODES 4 and 5 with all RCPs idle. ACTIONS CONDITION A. Valve not secured in closed position. REQUIRED ACTION A.1 Suspend all operations involving positive reactivity changes AND A.2 Initiate actions to secure valve in closed position. AND A.3 Perform SDM verification in accordance with SR 3.1.1.1. COMPLETION TIME Immediately Immediately 4 hours SURVEILLANCE REQUIREMENTS KEPCO & KHNP 43

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SR 3.1.12.1 Verify the valve that isolates unborated water sources is secured in the closed position. FREQUENCY 12 hours 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Linear Heat Rate CONDITION CONDITION Additional description is inserted (LHR) B. LHR not within region of B. One OPERABLE core to clarify the condition for the acceptable operation when the protection calculator (CPC) LHR. If the COLSS is not COLSS is out of service. calculated LHR not within available the OPERABLE LPD region of acceptable operation channels are monitored to when the COLSS is out of ensure that the LHR limit is not service. exceeded. SURVEILLANCE SURVEILLANCE SR 3.2.1.1 SR 3.2.1.1 Verify LHR, as indicated on each Verify LHR, as indicated on any SR 3.2.1.1 is revised from each OPERABLE local power density OPERABLE local power density to any for clarification. channel, is within its limit. channel, is within its limit. 3.2.2 Planar Radial FREQUENCY FREQUENCY Power ascension test plateaus Peaking Factors (Fxy) SR 3.2.2.1 SR 3.2.2.1 for the verification of the planar Once after each fuel loading with Once after each fuel loading with radial peaking factors are 20, 50, THERMAL POWER > 40% RTP THERMAL POWER > 40% RTP 80, and 100% for APR1400. but prior to operations above 70% but prior to operations above 80% RTP RTP 3.2.3 Azimuthal Power REQUIRED ACTION REQUIRED ACTION Tilt (Tq) B.2 B.2 Reduce Linear Power Level Reduce variable overpower trip

                         - High trip setpoints to  55% RTP.    (VOPT) setpoints to  55% RTP.

SURVEILLANCE SURVEILLANCE SR 3.2.3.1 SR 3.2.3.1

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

KEPCO & KHNP 44

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Only required to be met when Only applicable when Core COLSS is out of service. With Operating Limits Supervisory COLSS in service, this parameter System (COLSS) is out of service. is continuously monitored. With COLSS in service, this

                         -------------------------------------------  parameter is continuously monitored.

3.2.4 Departure From LCO 3.2.4 LCO 3.2.4 COLSS calculated core power Nucleate Boiling a. Maintaining Core Operating Limit a. Core Operating Limit operating limit is specified as a Ratio (DNBR) Supervisory System (COLSS) Supervisory System (COLSS) In function of thermal power in calculated core power less than or Service: Figure 3.2.4-1 for APR1400. equal to COLSS calculated core 1. Maintaining COLSS calculated Thus, figure index is increased power operating limit based on core power less than or equal to compared to NUREG-1432. DNBR (when COLSS is in service, COLSS calculated core power and either one or both control operating limit based on DNBR element assembly calculators when at least one control element (CEACs) are OPERABLE), assembly calculator (CEAC) is OPERABLE in each OPERABLE

b. Maintaining COLSS calculated core protection calculator (CPC) core power less than or equal to channel; or COLSS calculated core power 2. Maintaining COLSS calculated operating limit based on DNBR core power less than or equal to decreased by the allowance COLSS calculated core power specified in the COLR (when operating limit based on DNBR COLSS is in-service and neither decreased by the allowance CEAC is OPERABLE) specified in Figure 3.2.4-1 of the COLR when the CEAC requirements of LCO 3.2.4.a.1 are not met.

KEPCO & KHNP 45

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

c. Operating within the region of b. COLSS Out of Service:

acceptable operation of Figure 1. Operating within the region of 3.2.4-1 specified in the COLR acceptable operation of using any operable core Figure 3.2.4-2 specified in protection calculator (CPC) the COLR using any channel (when COLSS is out OPERABLE CPC channel of service and either one or when at least one CEAC is both CEACs are OPERABLE), OPERABLE in each or OPERABLE CPC channel; or

d. Operating within the region of 2. Operating within the region of acceptable operation of Figure acceptable operation of Figure 3.2.4-2 specified in the COLR 3.2.4-3 specified in the COLR using any operable CPC using any OPERABLE CPC channel (when COLSS is out of channel (with both CEACs service and neither CEAC is inoperable) when the CEAC OPERABLE). requirements of LCO 3.2.4.b.1 are not met.

SURVEILLANCE SURVEILLANCE COLSS calculated core power SR 3.2.4.1 Verify DNBR, as SR 3.2.4.1 Verify DNBR, as operating limit is specified as a indicated on all OPERABLE indicated on any OPERABLE function of thermal power in DNBR channels, is within the DNBR channel, is within the Figure 3.2.4-1 for APR1400. limit of Figure 3.2.4-1 or 3.2.4-2 limits of Figure 3.2.4-2 or Thus, figure index is increased of the COLR, as applicable. 3.2.4-3 of the COLR, as compared to NUREG-1432. applicable. 3.2.5 AXIAL SHAPE - Same as NUREG-1432 INDEX (ASI) 3.3 INSTRUMENTATION 3.3.1 Reactor Protective LCO 3.3.1 LCO 3.3.1 The LCO is changed to clarify System (RPS) Four RPS trip and bypass removal Four RPS trip and associated the bypass function and clarify Instrumentation - channels for each Function in automatic operating bypass the meaning of the bypass Operating Table 3.3.1-1 shall be OPERABLE. removal channels for each removal. Function in Table 3.3.1-1 shall be OPERABLE. KEPCO & KHNP 46

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CONDITION CONDITION The Condition and Required C. One or more Functions with one C. One or more Functions with one Action are changed to clarify the automatic bypass removal channel automatic operating bypass bypass function and clarify the inoperable. removal channel inoperable. meaning of the bypass removal. REQUIRED ACTION REQUIRED ACTION C.1 Disable bypass channel. C.1 Disable affected bypass C.2.2 Restore bypass removal channel. channel and associated automatic C.2.2 Restore automatic operating trip channel to OPERABLE status. bypass removal channel and associated automatic trip channel to OPERABLE status. CONDITION CONDITION D. One or more Functions with two One or more Functions with two automatic bypass removal automatic operating bypass channels inoperable. removal channels inoperable. REQUIRED ACTION REQUIRED ACTION D.1 Disable bypass channels. D.1 Disable affected bypass channels. CONDITION None Due to the platform change, E. One or more core protection channel function test is not calculator (CPC) channels with a performed in APR1400, when cabinet high temperature alarm. high temperature alarm of CPC is generated. The Common-Q platform has the compensation feature for temperature changes. For example, the analog module which is used in APR1400 has auto-calibration features against the temperature changes. Even if the high temperature alarm occurs, the system in the CPCS is able to perform its safety functions. KEPCO & KHNP 47

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) F. One or more CPC channels with None Due to the platform change, three or more autorestarts there is no auto restart function during a 12 hour period. in APR 1400. If processor has severe failure, the processor will be shut down and this will initiate the watchdog timer to generate the DNBR and LPD trips. Instead of the check for auto restart, the CPC System Event Log is checked every 12 hours to monitor the CPCS channel performance. G. Required Action and associated E. Required Action and associated Completion Time not met. Completion Time not met. SURVEILLANCE SURVEILLANCE See III.1.2.1 Tier 2, Table 7.2-4 SR 3.3.1.1 Perform a CHANNEL SR 3.3.1.1 Perform CHANNEL The function is not contained in CHECK of each RPS CHECK of each RPS instrument DCD Tier 2, Table 7.2-4, instrument channel except Loss channel. Reactor Protective System of Load. Design Input. SR 3.3.1.2 SR 3.3.1.2 THERMAL POWER for heat

                         -----------------NOTE-----------------     -----------------NOTE-----------------     balance calibration is Not required to be performed until         Not required to be performed until         considered.

12 hours after THERMAL POWER 12 hours after THERMAL POWER 70% RTP. 80% RTP. SR 3.3.1.3 Check the CPC auto SR 3.3.1.3 Check CPC System Due to the platform change, restart count. event log. there is no auto restart function in APR1400. Instead of the check for auto restart, the CPC System Event Log is checked every 12 hours to monitor the CPCS channel performance. KEPCO & KHNP 48

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.3.1.4 SR 3.3.1.4 The SR is changed to clarify the

                         -----------------NOTE-----------------     -----------------NOTES-----------------    meaning, considering operability
1. Not required to be performed 1. Not required to be performed and safety.

until 12 hours after THERMAL until 12 hours after THERMAL POWER 20% RTP. POWER 15% RTP.

2. The daily calibration may be 2. The daily power calibration may suspended during PHYSICS be suspended during PHYSICS TESTS, provided the calibration TESTS, provided calibration is is performed upon reaching performed upon reaching each each major test power plateau major test power plateau and and prior to proceeding to the prior to proceeding to the next next major test power plateau. major test power plateau.

Perform calibration (heat balance Perform the daily power calibration only) and adjust the linear power by calculating the core THERMAL level signals and the CPC POWER from the daily secondary addressable constant multipliers to heat balance measurement (a make the CPC T power and CPC calorimetric) and adjusting the nuclear power calculations agree linear power, CPC T power, and with the calorimetric, if the absolute CPC neutron flux power channels difference is [2]%. to agree with the calculated THERMAL POWER if any channel indicated more than 0.5% RTP less than the calculated THERMAL POWER. SR 3.3.1.5 SR 3.3.1.5 THERMAL POWER for heat

                         -----------------NOTE-----------------     -----------------NOTE-----------------     balance calibration is Not required to be performed until         Not required to be performed until         considered.

12 hours after THERMAL POWER 12 hours after THERMAL POWER 70% RTP. 80% RTP. KEPCO & KHNP 49

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.3.1.7 SR 3.3.1.7

                         -----------------NOTE-----------------     -----------------NOTE-----------------     See III.1.2.3                    Tier 2, Table 7.2-1
2. Not required to be performed for 2. Not required to be performed for logarithmic power level Logarithmic Power Level - High channels until 2 hours after until 2 hours after reducing reducing logarithmic power logarithmic power below 1E-3%

below 1E-4% and only if reactor and only if reactor trip circuit trip circuit breakers (RTCBs) are breakers (RTCBs) are open. closed. ------------------------------------------ Perform CHANNEL FUNCTIONAL Perform CHANNEL FUNCTIONAL TEST for each RPS See III.1.2.1 Tier 2, Table 7.2-4 TEST on each channel except instrumentation channel in The function is not contained in Loss of Load and power range accordance with the Setpoint DCD Tier 2, Table 7.2-4, neutron flux in accordance with the Control Program. Reactor Protective System Setpoint Control Program. Design Input. SR 3.3.1.8 SR 3.3.1.8

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

Neutron detectors are excluded Excore neutron detectors are from the CHANNEL excluded from CHANNEL CALIBRATION. CALIBRATION. Perform CHANNEL CALIBRATION Perform CHANNEL CALIBRATION of the power range neutron flux of linear power of excore neutron channels in accordance with the flux channel in accordance with the Setpoint Control Program. Setpoint Control Program. SR 3.3.1.9 None

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

[ Not required to be performed until 2 hours after THERMAL POWER 55% RTP. Perform CHANNEL FUNCTIONAL TEST for Loss of Load Function in accordance with the Setpoint KEPCO & KHNP 50

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Control Program. SR 3.3.1.10 SR 3.3.1.9

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

Neutron detectors are excluded Excore neutron detectors are from CHANNEL CALIBRATION. excluded from CHANNEL

                         ------------------------------------------ CALIBRATION.

Perform CHANNEL CALIBRATION ------------------------------------------ on each channel, including bypass Perform CHANNEL CALIBRATION removal functions in accordance on each trip channel, including with the Setpoint Control Program. automatic operating bypass removal functions in accordance with the Setpoint Control Program. SR 3.3.1.11 SR 3.3.1.10 SR 3.3.1.12 SR 3.3.1.11 Using the incore detectors, verify Using incore detectors, verify the shape annealing matrix shape annealing matrix elements elements to be used by the CPCs. to be used by the CPCs in accordance with the Setpoint Control Program. SR 3.3.1.13 SR 3.3.1.12 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on each TEST on each automatic operating automatic bypass removal function. bypass removal channel. SR 3.3.1.14 SR 3.3.1.13

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

Neutron detectors are excluded. Excore neutron detectors are

                         ------------------------------------------ excluded.

Table 3.3.1-1 Table 3.3.1-1

1. Linear Power Level - High 1. Variable Overpower
8. Steam Generator #1 Level - Low 8. Steam Generator #1 Water Level KEPCO & KHNP 51

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

                                                                     - Low
9. Steam Generator #2 Level - Low 9. Steam Generator #2 Water Level
                                                                     - Low
10. Steam Generator #1 Water Level - High
11. Steam Generator #2 Water Level - High 10 Reactor Coolant Flow, Steam 12. Reactor Coolant Flow, Steam (c)

Generator #1 - Low Generator #1 - Low

13. Reactor Coolant Flow, Steam
11. Reactor Coolant Flow, Steam Generator #2 - Low (c)

Generator #2 - Low (c)(d)

12. Loss of Load (turbine stop 14. Local Power Density - High (d) valve control oil pressure) 15. Departure From Nucleate
13. Local Power Density - High Boiling Ratio (DNBR) -

(c) (c)(d)

14. Departure From Nucleate Low (c)

Boiling Ratio (DNBR) - Low Table 3.3.1-1 Table 3.3.1-1 See III.1.2.3 Pointers to LCO 3.1.9 states that trip SURVEILLANCE Note (a) Note (a) function 2, Logarithmic Power REQUIREMENTS Bypass may be enabled when Trip may be bypassed when Level - High, in Table 3.3.1-1 is are updated. logarithmic power is > [1E-4]% and logarithmic power is > 1E-3%. applied to the special test shall be capable of automatic Operating bypass shall be exception. removal whenever logarithmic automatically removed when power is > [1E-4]%. Bypass shall logarithmic power is 1E-3%. be removed prior to reducing Trip may be manually logarithmic power to a value bypassed during PHYSICS [1E-4]%. Trip may be manually TESTS pursuant to LCO 3.1.9, bypassed during physics testing Special Test Exception (STE) pursuant to LCO 3.4.17, "RCS - SHUTDOWN MARGIN Loops - Test Exceptions." (SDM). Note (b) Note (b) See III.1.2.4 The setpoint may be decreased to Pressurizer Pressure - Low trip a minimum value of [300] psia, as setpoint may be decreased as KEPCO & KHNP 52

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) pressurizer pressure is reduced, pressurizer pressure is reduced to 2 provided the margin between 7.0 kg/cm A (100 psia). The pressurizer pressure and the margin between pressurizer setpoint is maintained [400] psi. pressure and the setpoint shall be 2 Bypass may be enabled when maintained at 28.1 kg/cm A (400 pressurizer pressure is < [500] psia psia). The operating bypass shall and shall be capable of automatic be removed automatically at 35.2 2 removal whenever pressurizer kg/cm A (500 psia). The setpoint pressure is < [500] psia. Bypass shall be increased automatically to shall be removed prior to raising the normal setpoint as pressurizer pressurizer pressure to a value pressure is increased. [500] psia. The setpoint shall be automatically increased to the normal setpoint as pressurizer pressure is increased. Note (c) Note (c) LCO 3.1.9 states that trip Bypass may be enabled when Trip may be manually bypassed function 2, Logarithmic Power logarithmic power is < [1E-04]% when logarithmic power is Level - High, in Table 3.3.1-1 is and shall be capable of automatic < 1E-4%. Operating bypass shall applied to the special test removal whenever logarithmic be automatically removed when exception. power is < [1E-4]%. Bypass shall logarithmic power is 1E-4%. be removed prior to raising During testing pursuant to LCO logarithmic power to a value 3.1.9, trip may be bypassed below [1E-4]%. During testing 5% RTP. Operating bypass shall pursuant to LCO 3.4.17, bypass be automatically removed when may be enabled when THERMAL THERMAL POWER is > 5% RTP. POWER is < [5]% RTP and shall be capable of automatic removal whenever THERMAL POWER is < [5]% RTP. Bypass shall be removed above 5% RTP. KEPCO & KHNP 53

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Note (d) Note (d) Bypass may be enabled when The OPERABILITY of the Local THERMAL POWER is < [55]% Power Density - High and DNBR - RTP and shall be capable of Low Functions includes the CPC automatic removal whenever auxiliary trips. THERMAL POWER is < [55]% RTP. Bypass shall be removed prior to raising THERMAL POWER to a value [55]% RTP. 3.3.2 Reactor Protective LCO 3.3.2 LCO 3.3.2 The LCO is changed to reflect System (RPS) Four RPS Logarithmic Power Level Four RPS trip and associated the functions listed in Table Instrumentation - - High trip channels and automatic operating bypass 3.3.2-1. Shutdown associated instrument and removal channels for each bypass removal channels shall Function in Table 3.3.2-1 shall be OPERABLE. be OPERABLE. APPLICABILITY APPLICABILITY Since Table 3.3.2-1 includes MODES 3, 4, and 5, with any According to Table 3.3.2-1. corresponding trip functions, reactor trip circuit breakers applicability MODES or other (RTCBs) closed and any control specified conditions, and element assembly capable of being surveillance requirements, the withdrawn. applicability is simplified.

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

Bypass may be enabled when logarithmic power is > [1E-4]% and shall be capable of automatic removal whenever logarithmic power is > [1E-4]%. Bypass shall be removed prior to reducing logarithmic power to a value [1E-4]%. KEPCO & KHNP 54

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) ACTIONS ACTIONS None -----------------NOTE----------------- NOTE is added to clarify the Separate Condition entry is application of the Completion allowed for each RPS Function. Time rules. The Conditions of

                                                              ------------------------------------------ this Specification may be entered independently for each function. The Completion Times of each inoperable function will be tracked separately for each function starting from the time the Condition was entered for that function.

CONDITION CONDITION Trip functions are described in A. One RPS logarithmic power A. One or more Functions with one detail as shown in Table 3.3.2-1. level trip channel inoperable. automatic RPS trip channel inoperable. B. Two RPS logarithmic power B. One or more Functions with two level trip channels inoperable. automatic RPS trip channels inoperable. C. One automatic bypass removal C. One automatic operating bypass channel inoperable. removal channel inoperable. D. Two automatic bypass removal D. Two automatic operating bypass channels inoperable. removal channels inoperable. REQUIRED ACTION REQUIRED ACTION A.1 Place channel in bypass or trip. A.1 Place trip channel in bypass or trip. A.2 Restore channel to A.2 Restore trip channel to OPERABLE status. OPERABLE status. B.1 Place one channel in bypass B.1 Place one trip channel in and place the other in trip bypass and the other in trip. C.1 Disable bypass channel. C.1 Disable affected bypass channel. KEPCO & KHNP 55

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) C.2.2 Restore bypass removal C.2.2 Restore automatic operating channel and associated automatic bypass removal channel and trip channel to OPERABLE status. associated automatic trip channel to OPERABLE status. D.1 Disable bypass channels. D.1 Disable affected bypass channels. SURVEILLANCE SURVEILLANCE Note is added to refer to table Table 3.3.2-1 is None -----------------NOTE----------------- 3.3.2-1 for each SR. added. Refer to Table 3.3.2-1 to determine which SR shall be performed for each RPS Function. SR 3.3.2.1 SR 3.3.2.1 Perform a CHANNEL CHECK of Perform CHANNEL CHECK of each logarithmic power channel. each RPS instrument channel. SR 3.3.2.2 SR 3.3.2.2 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on each TEST on each RPS trip channel in logarithmic power channel in accordance with the Setpoint accordance with the Setpoint Control Program. Control Program. SR 3.3.2.3 SR 3.3.2.3 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on each TEST on each automatic operating automatic bypass removal bypass removal function. function. SR 3.3.2.4 SR 3.3.2.4 Perform a CHANNEL Perform CHANNEL CALIBRATION CALIBRATION on each logarithmic on each RPS trip channel, power channel, including bypass including automatic operating removal function in accordance bypass removal function in KEPCO & KHNP 56

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) with the Setpoint Control Program. accordance with the Setpoint Control Program. None Table 3.3.2-1 3.3.3 Control Element LCO 3.3.3 LCO 3.3.3 See III.1.2.8 Assembly Two CEACs shall be OPERABLE. Two CEACs shall be OPERABLE Calculators in each Core Protection Calculator (CEACs) System (CPCS) channel. ACTIONS ACTIONS See III.1.2.8 None -----------------NOTE----------------- Separate Condition entry is allowed The NOTE is added to allow for each CPCS channel. CEAC inoperable in each

                                                            ------------------------------------------ channel.

CONDITION CONDITION A. One CEAC inoperable. A. One CEAC inoperable in one or more CPCS channels. REQUIRED ACTION REQUIRED ACTION See III.1.2.8 A.1 Perform SR 3.1.4.1. A.1 Declare affected CPCS channel(s) inoperable. A.1 action is added to declare AND the affected channel inoperable. OR A.2 Restore CEAC to OPERABLE status. A.2.1 Verify indicated position of each full and part strength CEA is within 16.8 cm (6.6 in) of all other CEAs in its group. AND A.2.2 Restore CEAC to OPERABLE status. KEPCO & KHNP 57

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CONDITION CONDITION See III.1.2.8 B. Both CEACs inoperable. B. Both CEACs inoperable in one or more CPCS channels. REQUIRED ACTION REQUIRED ACTION See III.1.2.8. None B.1 Declare affected channel(s) inoperable. B.1 is added to specify the case both CEACs inoperable in one or OR more CPCS channels. B.1 Verify the departure from B.2.1 Verify indicated position of Same action as in SR 3.1.4.1. nucleate boiling ratio each full and part strength Completion time 4 hours used requirement of LCO 3.2.4, CEA is within 16.8 cm instead of 7 inches and 12 hours "Departure from nucleate (6.6 in) of all other CEAs in boiling ratio (DNBR)", is met its group. [and the Reactor Power Cutback System is disabled]. AND AND B.2.2 Verify departure from nucleate boiling ratio B.2 Verify all full strength and part requirement of LCO 3.2.4 strength CEA groups are fully is met and Reactor Power withdrawn and maintained fully Cutback System (RPCS) is withdrawn, except during disabled. Surveillance testing pursuant to SR 3.1.4.3[or for control, when CEA group #6 may be AND inserted to a maximum of 127.5 inches. B.2.3 Verify all full strength and See II.5 part strength CEA groups AND are fully withdrawn and #6 is changed into #5 which is maintained fully withdrawn, the last control group in B.3 Verify the "RSPT/CEAC except during Surveillance APR1400. Inoperable" addressable testing pursuant to SR constant in each core 3.1.4.3, or for power control, protection calculator (CPC) is when CEA group #5 may be set to indicate that both inserted to a maximum of KEPCO & KHNP 58

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CEACs are inoperable. 323.9 cm (127.5 in). AND AND B.4 Verify the Control Element B.2.4 Verify addressable constant See III.1.2.8 Drive Mechanism Control in each affected CPC is set System is placed in "OFF" and to indicate that both CEACs maintained in "OFF", except are inoperable and during CEA motion permitted "RSPT/CEAC inoperable" by Required Action B.2. status is indicated. AND AND B.5 Perform SR 3.1.4.1. B.2.5 Verify Digital Rod Control "Standby" in APR1400 is "OFF" System (DRCS) is placed in in CEDMCS of STS. Current TS value "standby" and maintained in used "standby", except during CEA motion permitted by Required Action B.2.2. CONDITION CONDITION Same as in TS 3.3.2, it is not C. Receipt of a CPC channel B or C. Required Action and associated necessary to include high C cabinet high temperature Completion Time of Condition B temperature alarm. alarm. not met. Auto restart function has been removed. KEPCO & KHNP 59

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION Due to the platform change, C.1 Perform CHANNEL C.1 Be in MODE 3. channel function test is not FUNCTIONAL TEST on performed in APR1400, when affected CEAC(s). high temperature alarm of CPC is generated. Due to the platform change, there is no auto restart function in APR1400. Instead of the check for auto restart, the CPC System Event Log is checked every 12 hours to monitor the CPCS channel performance. COMPLETION TIME COMPLETION TIME Due to the platform change, C.1 12 hours C.1 6 hours channel function test is not performed in APR1400, when high temperature alarm of CPC CONDITION CONDITION is generated. D. One or two CEACs with three or None Due to the platform change, more auto restarts during a 12 there is no auto restart function hour period. in APR1400. Instead of the check for auto restart, the CPC REQUIRED ACTION System Event Log is checked D.1 Perform CHANNEL every 12 hours to monitor the FUNCTIONAL TEST on CPCS channel performance. affected CEAC. COMPLETION TIME 24 hours CONDITION CONDITION E. Required Action and associated None Completion Time of Condition B, C, or D not met. REQUIRED ACTION E.1 Be in MODE 3. KEPCO & KHNP 60

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) COMPLETION TIME 6 hours SURVEILLANCE SURVEILLANCE Due to the platform change, SR 3.3.3.2 Check the CEAC auto SR 3.3.3.2 there is no auto restart function restart count. Check CPC system event log. in APR1400. Instead of the check for auto restart, the CPC FREQUENCY FREQUENCY System Event Log is checked 12 hours 12 hours every 12 hours to monitor the CPCS channel performance. OR In accordance with the Surveillance Frequency Control Program SR 3.3.3.5 Perform a CHANNEL SR 3.3.3.5 Perform CHANNEL The contents are clarified. FUNCTIONAL TEST in FUNCTIONAL TEST in accordance with the Setpoint accordance with the Setpoint Control Program. Control Program (including annunciation and trip function test). SR 3.3.3.6 Verify the isolation None Due to the platform change, characteristics of each CEAC there is no amplifier and optical isolation amplifier and each isolator for CEAC to CPC. optical isolator for CEAC to CPC data transfer in Fiber optic high speed datalink is accordance with the Setpoint used to interface for CEAC to Control Program. CPC KEPCO & KHNP 61

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.3.4 Reactor Protective LCO 3.3.4 LCO 3.3.4 See III.1.2.5 System (RPS) Six channels of RPS Matrix Logic, Four RPS logic channels Logic four channels of RPS Initiation (Coincidence, Initiation Logic), four and Trip Initiation Logic, [four channels of reactor trip channels of reactor trip circuit circuit breakers (RTCBs),] and four breakers (RTCBs), and four channels of Manual Trip shall be channels of Manual Trip shall be OPERABLE. OPERABLE. CONDITION CONDITION See III.1.2.5 A. One Matrix Logic channel None inoperable. OR Three Matrix Logic channels inoperable due to a common power source failure de-energizing three matrix power supplies. B. One channel of manual Trip, A. --------------NOTE-------------- The RTCB condition for channel RTCBs, or Initiation Logic RTCBs associated with one functional test is added. inoperable in MODE 1 or 2. inoperable channel may be closed for up to 1 hour for the performance of an RPS Testing on the OPERABLE CHANNEL FUNCTIONAL channels cannot be performed TEST. without causing a reactor trip,

                                                                    ------------------------------------- unless the RTCBs in the One channel of Manual Trip,           inoperable channels are closed RTCB, or RPS logic inoperable to permit testing. Therefore, the in MODE 1 or 2.

Note has been added specifying that the RTCBs associated with one inoperable channel may be closed for up to 1 hour for the performance of an RPS CHANNEL FUNCTIONAL TEST. KEPCO & KHNP 62

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) C. One channel of manual Trip, B. --------------NOTE-------------- The RTCB condition for channel RTCBs, or Initiation Logic RTCBs associated with one function test is added. inoperable in MODE 3, 4, or 5. inoperable channel may be closed for up to 1 hour for the Testing on the OPERABLE performance of an RPS channels cannot be performed CHANNEL FUNCTIONAL without causing a reactor trip, TEST. unless the RTCBs in the

                                                                   ------------------------------------- inoperable channels are closed One channel of Manual trip,           to permit testing. Therefore, the RTCB, or RPS logic                    Note has been added specifying inoperable in MODE 3, 4, or 5.        that the RTCBs associated with one inoperable channel may be closed for up to 1 hour for the performance of an RPS CHANNEL FUNCTIONAL TEST.

D. Two channels of Manual Trip, None RTCBs, or Initiation Logic affecting the same trip leg inoperable. E. Required Action and associated C. Required Action and associated See III.1.2.5 Completion Time of Condition Completion Time of Condition A A, B, or D not met. not met. OR OR One or more Functions with One or more Functions with more than one Manual Trip, more than one channel of Matrix Logic, Initiation Logic, or Manual Trip, RTCB, or RPS RTCB channel inoperable for logic inoperable. reasons other than Condition A or D. KEPCO & KHNP 63

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE The SRs for RPS logic channel SR 3.3.4.1 Perform a CHANNEL SR 3.3.4.1 Perform CHANNEL and RTCB channel are merged FUNCTION TEST on each RTCB FUNCTION TEST on each RPS into SR 3.3.4.1. channel. logic channel and RTCB channel. SR 3.3.4.2 Perform a CHANNEL FUNCTION TEST on each RPS Logic channel. SR 3.3.4.3 SR 3.3.4.2 The SRs for RPS logic channel SR 3.3.4.4 SR 3.3.4.3 and RTCB channel are merged into SR 3.3.4.1, subsequent SRs are renumbered and APR1400 SR 3.3.4.4 shall be deleted. 3.3.5 Engineered Safety LCO 3.3.5 LCO 3.3.5 Features Four ESFAS trip and bypass Four ESFAS trip and associated Actuation System removal channels for each automatic operating bypass (ESFAS) Function in Table 3.3.5-1 shall be removal channels for each Instrumentation OPERABLE. Function in Table 3.3.5-1 shall be OPERABLE. CONDITION CONDITION C. One or more Functions with one C. One or more Functions with one automatic bypass removal channel automatic operating bypass inoperable. removal channel inoperable. D. One or more Functions with two D. One or more Functions with two automatic bypass removal automatic operating bypass channels inoperable. removal channels inoperable. None F. Required Action and associated Completion Time not met. REQUIRED ACTION REQUIRED ACTION A.1 Place channel in bypass or trip. A.1 Place trip channel in bypass or trip. A.2 Restore channel to A.2 Restore trip channel to OPERABLE status. OPERABLE status. KEPCO & KHNP 64

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) B.1 Place one channel in bypass B.1 Place one trip channel in and the other in trip. bypass and the other in trip. C.1 Disable bypass channel. C.1 Disable affected bypass channel. C.2.2 Restore bypass removal C.2.2 Restore automatic operating channel and associated bypass removal channel and automatic trip channel to associated automatic trip OPERABLE status. channel to OPERABLE status. D.1 Disable bypass channels. D.1 Disable affected bypass channels. E.2 Be in MODE 4. E.2 Be in MODE 4 without reliance on SGs for heat removal. None F.1 Be in MODE 3. None F.2 Be in MODE 5. None (For Item E.1) Applicable MODES for AFAS are

                                                               --------------NOTE--------------      extended from MODES 1, 2, Only applicable to Functions 5        and 3 to MODES 1, 2, 3, and 4 and 6 of Table 3.3.5-1.               with reliance on SGs for heat
                                                               ------------------------------------- removal in order to enhance the safety of nuclear power plants.

None (For Item F.1) Applicable MODES for ESFAS Tier 2, Table 7.2-4,

                                                               --------------NOTE--------------      functions such as SIAS, CIAS,    Note (5)

Only applicable to Functions 1, CSAS, and MSIS are extended 2, 3, and 4 of Table 3.3.5-1 from MODES 1, 2, and 3 to Tier 2, Table 7.2-1

                                                               ------------------------------------- MODES 1, 2, 3, and 4 in order to enhance the safety of nuclear power plants.

SURVEILLANCE SURVEILLANCE SR 3.3.5.3 Perform a CHANNEL SR 3.3.5.3 Perform CHANNEL CALIBRATION of each ESFAS CALIBRATION of each ESFAS channel, including bypass removal channel, including automatic functions in accordance with the operating bypass removal function Setpoint Control Program. in accordance with the Setpoint Control Program. KEPCO & KHNP 65

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.3.5.4 Verify ESF RESPONSE SR 3.3.5.4 Verify ESFAS TIME is within limits. RESPONSE TIME is within limits. SR 3.3.5.5 Perform a CHANNEL SR 3.3.5.5 Perform CHANNEL FUNCTIONAL TEST on each FUNCTIONAL TEST on each automatic bypass removal automatic operating bypass channel. removal channel. Table 3.3.5-1 Table 3.3.5-1 Applicable MODES for ESFAS In APR1400 notes APPLICABLE MODES OR OTHER APPLICABLE MODES OR OTHER functions such as SIAS, CSAS, (b) and (d) are SPECIFIED CONDITIONS: 1,2,3 SPECIFIED CONDITIONS: 1,2,3,4 and MSIS are extended from related to the MODES 1, 2, and 3 to Applicable MODES. MODES 1, 2, 3, and 4 in order to enhance the safety of nuclear power plants. Table 3.3.5-1 Table 3.3.5-1

1. Safety Injection Actuation 1. Safety Injection Actuation Signal (a) (a)

Signal 1.b. Pressurizer Pressure - Low (b) 1.b. Pressurizer Pressure - low None (a) 2.b. Automatic SIAS 3.b. Pressurizer Pressure - Low (b) 3.b. Pressurizer Pressure - low Table 3.3.5-1 Table 3.3.5-1 None 4.c Steam Generator Level - High Table 3.3.5-1 Table 3.3.5-1 See III.1.2.2

5. Recirculation Actuation Signal None Table 3.3.5-1 Table 3.3.5-1 See III.1.2.2
6. Emergency Feedwater Actuation 5. Auxiliary Feedwater Actuation Signal SG #1 (EFAS-1) Signal SG #1 (AFAS-1)
b. SG Pressure Difference - None High

[c. Steam Generator Pressure None

                              - Low
7. Emergency Feedwater Actuation 6. Auxiliary Feedwater Actuation Signal SG #2 (EFAS-2) Signal SG #2 (AFAS-2)
b. SG Pressure Difference - None High KEPCO & KHNP 66

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) [c. Steam Generator Pressure None

                              - Low Table 3.3.5-1                         N/A                                   See III.1.2.2                    Tier 2, Table 7.2-4, Note                                                                                                         Note (5)

(a) Automatic SIAS also initiates a Containment Cooling Actuation Tier 2, Table 7.2-1 Signal (CCAS). Table 3.3.5-1 Table 3.3.5-1 See III.1.2.2 Note Note (b) The setpoint may be decreased (a) The setpoint may be manually to a minimum value of [300] decreased to a minimum value 2 psia, as pressurizer pressure is of 7.0 kg/cm A (100 psia), as reduced, provided the margin pressurizer pressure is between pressurizer pressure reduced, provided the margin and the setpoint is maintained between pressurizer pressure [400] psia. Trips may be and the setpoint is maintained 2 bypassed when pressurizer 28.1 kg/cm (400 psi). Trips pressure is < [400] psia. may be bypassed when Bypass shall be automatically pressurizer pressure is < 28.1 2 removed when pressurizer kg/cm A (400 psia). Bypass pressure is [500] psia. The shall be automatically removed setpoint shall be automatically when pressurizer pressure is 2 increased to the normal 35.2 kg/cm A (500 psia). The setpoint as pressurizer setpoint shall be automatically pressure is increased. increased to the normal setpoint as pressurizer pressure is increased. Table 3.3.5-1 Table 3.3.5-1 Note Note (d) The Main Steam Isolation (b) Main Steam Isolation Signal Signal (MSIS) Function (Steam (MSIS) Function (Steam Generator Pressure - Low and Generator Pressure - Low, Containment Pressure - High Containment Pressure - High, signals) is not required to be and Steam Generator Level - OPERABLE when all High signals) is not required to KEPCO & KHNP 67

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) associated valves isolated by be OPERABLE when all the MSIS Function are closed associated valves isolated by and [de-activated]. the MSIS Function are closed and deactivated. Table 3.3.5-1 Table 3.3.5-1 Note Note None (d) When a steam generator is relied upon for heat removal. 3.3.6 Engineered Safety LCO 3.3.6 LCO 3.3.6 See III.1.2.5 Features Six channels of ESFAS Matrix The ESFAS Coincidence Logic, Actuation System Logic, four channels of ESFAS Initiation Logic, Actuation Logic, (ESFAS) Logic Initiation Logic, two channels of Manual Trip and Diverse Manual and Manual Trip Actuation Logic, and two channels ESF Actuation channels required of Manual Trip shall be for each Function in Table 3.3.6-1 OPERABLE for each Function in shall be OPERABLE. Table 3.3.6-1. ACTIONS ACTIONS

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

Separate Condition entry is allowed Separate Condition entry is allowed for each Function. for each ESFAS Function and for

                         ------------------------------------------ each Diverse Manual ESF Actuation Function.

KEPCO & KHNP 68

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CONDITION CONDITION See III.1.2.5 A. ------------------NOTE----------------- A. One or more Functions with one This action also applies when three Coincidence Logic channel, CONDITION A and B of Matrix Logic channels are Initiation Logic channel, or NUREG-1432 are integrated into inoperable due to a common power Manual Trip channel inoperable. CONDITION A of APR1400. source failure de-energizing three matrix power supplies. One or more Functions with one Matrix Logic channel inoperable. B. One or more Functions with one Manual Trip or Initiation Logic channel inoperable E. Two Actuation Logic channels D. One or more Diverse Manual inoperable. ESF Actuation Functions with one channel inoperable. OR Required Action and associated Completion Time no met. E. Required Action and associated Completion Time of Condition A, B, C, or D not met. OR One or more Functions with two or more Actuation Logic channels inoperable. KEPCO & KHNP 69

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION E.2 --------------NOTE-------------- E.2 --------------NOTE-------------- LCO 3.0.4.a is not applicable Only applicable to Functions 5, when entering MODE 4. 6, 7.c, and 7.d of Table

                               -------------------------------------       3.3.6-1.

Be in MODE 4. ------------------------------------- Be in MODE 4 without reliance COMPLETION TIME upon SGs for heat removal. E.2 12 hours AND E.3 --------------NOTE-------------- Only applicable to Functions 1, 2, 3, 4, 7.a, 7.b, 7.e, and 7.f of Table 3.3.6-1. Be in MODE 5. COMPLETION TIME E.2 36 hours E.3 36 hours SURVEILLANCE SURVEILLANCE NUREG-1432 SR 3.3.6.1 and SR 3.3.6.1 SR 3.3.6.1 (merged) SR 3.3.6.3 are merged into SR 3.3.6.3 APR1400 SR 3.3.6.1. SURVEILLANCE SURVEILLANCE See III.1.2.6 SR 3.3.6.2 SR 3.3.6.2

                         ----------NOTE---------------------         ----------NOTES---------------------

Relays exempt from testing during 1. Components exempt from operation shall be tested during testing during operation shall each MODE 5 entry exceeding be tested once every 18 24 hours unless tested during the months (MODE 6) or in KEPCO & KHNP 70

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) previous 6 months. MODE 5 if not tested within the

                         ---------------------------------------       previous 62 days.
2. The pair of Actuation Logic Perform a subgroup relay test of subgroup channels A and C each Actuation Logic channel, and the pair of Actuation Logic which includes the de-energization subgroup channels B and D of each subgroup relay and shall be tested on a staggered verification of the OPERABILITY of basis.

each subgroup relay. --------------------------------------- Perform a verification of the OPERABILITY of subgroup for Actuation signal of each Actuation Logic channel. SR 3.3.6.3 SR 3.3.6.3 See III.1.2.7 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on each TEST on each Diverse Manual SR 3.3.6.3 does not include a ESFAS Manual Trip channel. ESF Actuation channel. Channel Functional Test on each ESFAS manual trip channel because CONDITION A and B of NUREG-1432 are integrated into CONDITION A of APR1400. Table 3.3.6-1 Table 3.3.6-1 See III.1.2.2 In APR1400 FUNCTION FUNCTION REQUIRED

1. Safety Injection Actuation Signal 1. Safety Injection Actuation Signal CHANNELS are
a. Matrix Logic a. Coincidence Logic listed for each
b. Initiation Logic b. Initiation Logic FUNCTION and
c. Actuation logic c. Actuation Logic APPLICABLE
d. Manual trip d. Manual Trip MODES are
2. Containment Isolation Actuation 2. Containment Spray Actuation updated.

Signal Signal

a. Matrix Logic a. Coincidence Logic
b. Initiation Logic b. Initiation Logic
c. Actuation logic c. Actuation Logic
d. Manual trip d. Manual Trip KEPCO & KHNP 71

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

3. Containment Cooling Actuation 3. Containment Isolation Actuation (a)

Signal Signal

a. Initiation Logic a. Coincidence Logic
b. Actuation logic b. Initiation Logic
c. Manual trip c. Actuation Logic
4. Recirculation Actuation Signal d. Manual Trip
a. Matrix Logic
b. Initiation Logic
c. Actuation logic
d. Manual trip
5. Containment Spray Actuation (b)

Signal

a. Matrix Logic
b. Initiation Logic
c. Actuation logic
d. Manual trip
6. Main Steam Isolation Signal 4. Main Steam Isolation Signal
a. Matrix Logic a. Coincidence Logic
b. Initiation Logic b. Initiation Logic
c. Actuation logic c. Actuation Logic
d. Manual trip d. Manual Trip
7. Emergency Feedwater Actuation 5. Auxiliary Feedwater Actuation Signal SG #1 (EFAS-1) Signal SG #1 (AFAS-1)

(a)

a. Matrix Logic a. Coincidence Logic 4 (a)
b. Initiation Logic b. Initiation Logic 4 (a)
c. Actuation logic c. Actuation Logic 4 (a)
d. Manual trip d. Manual Trip 4
8. Emergency Feedwater Actuation 6. Auxiliary Feedwater Actuation Signal SG #2 (EFAS-2) Signal SG #2 (AFAS-2)

(a)

a. Matrix Logic a. Coincidence Logic 4 (a)
b. Initiation Logic b. Initiation Logic 4 (a)
c. Actuation logic c. Actuation Logic 4 (a)
d. Manual trip d. Manual Trip 4
7. Diverse Manual ESF Actuation Signal
a. Safety Injection KEPCO & KHNP 72

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

b. Containment Spray
c. Auxiliary Feedwater (SG #1)

(a) 4

d. Auxiliary Feedwater (SG #2)

(a) 4

e. Main Steam Isolation per main steam isolation valve (MSIV)

(a) Automatic SIAS also initiates f. Containment Isolation CCAS (b) (a) Automatic SIAS also required for When a steam generator is relied automatic CSAS initiation. upon for heat removal 3.3.7 Diesel Generator - Same as NUREG-1432 (DG) - Loss of Voltage Start (LOVS) 3.3.8 Containment LCO 3.3.8 LCO 3.3.8 Purge Isolation One CPIS channel shall be One CPIAS instrument division Signal (CPIS) OPERABLE. with two area radiation monitor channels, one Manual Actuation division, and one Actuation Logic division shall be OPERABLE. APPLICABILITY APPLICABILITY MODES 1, 2, 3, and 4, MODES 1, 2, 3, and 4, During movement of [recently] MODE 5 with RCS loops not filled irradiated fuel assemblies within when relying on LCO 3.6.7.c.2, containment. MODE 6 when relying on LCO 3.6.7.c.2 or LCO 3.9.3.c.2.

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

Only required when the penetration ----------NOTE--------------------- is not isolated by at least one Only required when the associated closed and de-activated automatic containment purge or exhaust line valve, closed manual valve, or penetration flow path is not isolated blind flange. by at least one closed and deactivated automatic valve, KEPCO & KHNP 73

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

                         ---------------------------------------     closed manual valve, or blind flange.

CONDITION CONDITION A. CPIS Manual Trip, Actuation A. CPIAS required Manual Logic, or one or more required Actuation division, required channels of radiation monitors Actuation Logic division, or inoperable in MODES 1, 2, 3, required instrument division with and 4. one or more required area radiation monitor channels inoperable in MODES 1, 2, 3, and 4. REQUIRED ACTION REQUIRED ACTION Related B.2 --------------NOTE-------------- B.2 Be in MODE 5. See II.3.3 COMPLETION LCO 3.0.4.a is not applicable TIME is changed. when entering MODE 4. Be in MODE 4. CONDITION CONDITION See II.2.1 C. CPIS Manual Trip, Actuation C. CPIAS required Manual Logic, or one or more required Actuation division, required channels of radiation monitors Actuation Logic division, or inoperable during movement of required instrument division [recently] irradiated fuel assemblies with one or more required area within containment. radiation monitor channels inoperable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, or in MODE 5 with LCO 3.6.7.c.2 not met or in MODE 6 with LCO 3.6.7.c.2 or LCO 3.9.3.c.2 not met. KEPCO & KHNP 74

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION See II.2.1 C.2 Suspend movement of C.2.1 Suspend CORE [recently] irradiated fuel ALTERATIONS. assemblies in containment. AND C.2.2 Suspend movement of irradiated fuel assemblies in containment. SURVEILLANCE SURVEILLANCE SR 3.3.8.1 SR 3.3.8.1 Perform a CHANNEL CHECK on Perform CHANNEL CHECK on required containment area and required containment upper gaseous radiation monitor channel. operating area radiation monitor channel and operating area radiation monitor channel. SR 3.3.8.2 N/A Perform a CHANNEL CHECK on required containment particulate and iodine radiation monitor channel. SR 3.3.8.3 SR 3.3.8.2

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

Only required to be met in MODES Only required to be met in MODES 1, 2, 3, and 4. 1, 2, 3, and 4. Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on each TEST on each required upper required containment radiation operating area radiation monitor monitor channel in accordance with channel and each required the Setpoint Control Program. operating area radiation monitor channel in accordance with the Setpoint Control Program. KEPCO & KHNP 75

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.3.8.4 SR 3.3.8.3 See II.2.1

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

Only required to be met during Only required to be met during movement of irradiated fuel CORE ALTERATIONS and during assemblies within containment. movement of irradiated fuel

                         ------------------------------------------ assemblies within containment, Perform a CHANNEL                          and in MODE 5 with RCS loops not FUNCTIONAL TEST on required                filled when relying on LCO containment radiation monitor              3.6.7.c.2, and in MODE 6 when channel in accordance with the             relying on LCO 3.6.7.c.2 or LCO Setpoint Control Program.                  3.9.3.c.2.

Perform CHANNEL FUNCTIONAL TEST on each required upper operating area radiation monitor channel and each required operating area radiation monitor channel in accordance with the Setpoint Control Program. SR 3.3.8.5 SR 3.3.8.4

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

Surveillance of Actuation Logic Surveillance of Actuation Logic shall include the actuation of each shall include actuation of each initiation relay and verification of initiation circuit and verification of the proper operation of each proper operation of each initiation initiation relay. circuit. Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on required TEST on required CPIAS Actuation CPIS Actuation Logic channel. Logic division. SR 3.3.8.8 SR 3.3.8.7 Perform CHANNEL FUNCTIONAL Perform CHANNEL FUNCTIONAL TEST on required CPIS Manual TEST on required CPIAS Manual Trip channel. Actuation division. 3.3.9 Control Room LCO 3.3.9 LCO 3.3.9 KEPCO & KHNP 76

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Isolation Signal One CRIS channel shall be One CREVAS instrument division (CRIS) OPERABLE. with one radiation monitor channel, one Manual Actuation division, and one Actuation Logic division shall be OPERABLE. APPLICABILITY APPLICABILITY See II.2.1 MODES 1, 2, 3, 4, [5, and 6], MODES 1, 2, 3, and 4, During movement of [recently] During CORE ALTERATIONS, irradiated fuel assemblies. During movement of irradiated fuel assemblies. CONDITION CONDITION A. CRIS Manual Trip, Actuation A. CREVAS required Manual Logic, or [one or more required Actuation division, required channels of particulate/iodine or Actuation Logic division, or gaseous] radiation monitors required instrument division with inoperable in MODES 1, 2, 3, or 4. one required radiation monitor channel inoperable in MODE 1, 2, 3, or 4. REQUIRED ACTION REQUIRED ACTION The REQUIRED ACTION A.1 ---------------NOTE-------------- A.1 reflects APR1400 design feature. Place Control Room APR1400 does not have toxic Emergency Air Cleanup gas protection mode. System (CREACS) in toxic gas protection mode if automatic transfer to toxic gas protection mode inoperable. Place one CREACS train in Place one Control Room Area emergency radiation protection heating, ventilation, and air mode. conditioning (HVAC) System train in emergency operation mode. KEPCO & KHNP 77

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) B.2 --------------NOTE-------------- B.2 Be in MODE 5. See II.3.3 Related LCO 3.0.4.a is not applicable COMPLETION when entering MODE 4. TIME is changed. Be in MODE 4. CONDITION CONDITION See II.2.1 C. CRIS Manual Trip, Actuation C. CREVAS required Manual Logic, or required Actuation division, required particulate/iodine or gaseous Actuation Logic division, or radiation monitors inoperable required instrument division with [in MODE 5 or 6], or during one required radiation monitor movement of [recently] channel inoperable during CORE irradiated fuel assemblies. ALTERATIONS or movement of irradiated fuel assemblies. REQUIRED ACTION REQUIRED ACTION The REQUIRED ACTION C.1 ---------------NOTE-------------- C.1 reflects APR1400 design feature. Place CREACS in toxic gas protection mode if automatic transfer to toxic gas protection mode inoperable. Place one CREACS train in Place one Control Room Area emergency radiation HVAC System train in protection mode. emergency operation mode. C.2.2 -------------NOTE------------- C.2.2 Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM. Suspend positive reactivity Suspend positive reactivity additions. additions. KEPCO & KHNP 78

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) None C.2.3 Suspend CORE See II.2.1 ALTERATIONS. SURVEILLANCE SURVEILLANCE The SR reflects APR1400 design SR 3.3.9.3 SR 3.3.9.3 feature.

                         -----------------NOTES-----------------    -----------------NOTE-----------------
1. Surveillance of Actuation Logic Surveillance of Actuation Logic shall include the verification of shall include verification of proper the proper operation of each operation of each initiation circuit.

initiation relay. ------------------------------------------

2. Relays associated with plant Perform CHANNEL FUNCTIONAL equipment that cannot be TEST on required CREVAS operated during plant operation Actuation Logic division.

are required to be tested during each MODE 5 entry exceeding 24 hours unless tested within the previous 6 months. Perform a CHANNEL FUNCTIONAL TEST on required CRIS Actuation Logic channel. SR 3.3.9.5 SR 3.3.9.5 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on required TEST on required CREVAS CRIS Manual Trip channel. Manual Actuation division. SR 3.3.9.6 SR 3.3.9.6 [ Verify that response time of Verify that the response time of required CRIS channel is within required CREVAS division is within limits. limits. 3.3.10 Fuel Handling LCO 3.3.10 LCO 3.3.10 Isolation Signal One FHIS channel shall be One FHEVAS instrument division (FHIS) OPERABLE. with one radiation monitor channel, one Manual Actuation division, and one Actuation Logic division shall be OPERABLE. KEPCO & KHNP 79

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) APPLICABILITY APPLICABILITY [MODES 1, 2, 3, and 4,] During movement of irradiated fuel During movement of [recently] in the fuel handling area. irradiated fuel in the fuel building. ACTION ACTION The deviations reflect APR1400 Tier 2, 7.3.1.3

                         -----------------NOTE-----------------     None                                   design feature. Area radiation LCO 3.0.3 is not applicable.                                                      monitor is designed for           Item name is
                         ------------------------------------------                                        APR1400. Particulate/iodine or    changed.

gaseous radiation monitors is not See II.5 CONDITION CONDITION applicable to APR1400. A. [ Actuation Logic, Manual Trip, None or [one or more required FHEVAS is not applicable to channels of particulate/iodine MODES 1, 2, 3, and 4. and gaseous] radiation monitors inoperable in MODE 1, 2, 3, or 4.] B. [ Required Action and associated Completion Time of Condition A not met.] C. Actuation Logic, Manual Trip, or A. Required Manual Actuation [one or more required channels division, required Actuation Logic of particulate/iodine and division, or required instrument gaseous] radiation monitors division with required radiation inoperable during movement of monitor channel inoperable. [recently] irradiated fuel Assemblies. REQUIRED ACTION REQUIRED ACTION C.1 Place one OPERABLE FBACS A.1 Place one OPERABLE Fuel train in operation. Handling Area heating, ventilation, and air conditioning OR (HVAC) System train in emergency operation mode. C.2. Suspend movement of [recently] irradiated fuel OR assemblies in the fuel building. A.2. Suspend movement of KEPCO & KHNP 80

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) irradiated fuel assemblies in fuel handling area. SURVEILLANCE SURVEILLANCE SR 3.3.10.3 SR 3.3.10.3

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

Testing of Actuation Logic shall Testing of Actuation Logic shall include the actuation of each include actuation of each initiation initiation relay and verification of circuit and verification of proper the proper operation of each operation of each initiation circuit. ignition relay. ------------------------------------------

                         ------------------------------------------ Perform CHANNEL FUNCTIONAL Perform a CHANNEL                          TEST on required FHEVAS FUNCTIONAL TEST on required                Actuation Logic division.

FHIS Actuation Logic channel. SR 3.3.10.4 SR 3.3.10.4 Perform a CHANNEL Perform CHANNEL FUNCTIONAL FUNCTIONAL TEST on required TEST on required FHEVAS Manual FHIS Manual Trip logic. Actuation division. SR 3.3.10.6 SR 3.3.10.6 [ verify response time of required Verify that the response time of FHIS channel is within limits. required FHEVAS division is within limits. 3.3.11 Post Accident LCO 3.3.11 LCO 3.3.11 Changed to Monitoring The PAM instrumentation for each The AMI measurement channels measurement (PAM) Function in Table 3.3.11-1 shall be for each Function in Table 3.3.11-1 channel Instrumentation OPERABLE. shall be OPERABLE. throughout. KEPCO & KHNP 81

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) ACTION ACTION Note 1 has been added in the Tier 2, 7.5.1.1

                         -----------------NOTE----------------- -----------------NOTES----------------- ACTIONS to exclude the MODE Separate Condition entry is allowed    1. LCO 3.0.4 is not applicable.         change restriction of LCO 3.0.4. Item name is for each Function.                     2. Separate Condition entry is          This exception allows entry into  changed.
                         -------------------------------------      allowed for each Function.          the applicable MODE while         See II.5
                                                                -------------------------------------   relying on the ACTIONS, even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the passive function of the instruments, the operator's ability to monitor an accident using alternate instruments and methods, and the low probability of an event requiring these instruments.

COMPLETION TIME COMPLETION TIME See II.3.2 Tier 2, 7.5.1.1 A.1 30 days A.1 31 days Table 3.3.11-1 Table 3.3.11-1 NUREG-1432 Rev. 4 had Added FUNCTION FUNCTION followed RG 1.97 Rev. 3 (1983). FUNCTIONS and

1. [Wide Range] Neutron Flux 1. Logarithmic Reactor Power On the other hand, APR1400 associated (neutron flux) DCD is adapted in accordance requirements.
2. Reactor Coolant System Hot 2. Hot Leg temperature (Wide with RG 1.97 Rev. 4 (2006). A Leg Temperature Range) few variations are added in Tier 2, Table 7.5-1
3. Reactor Coolant System Cold 3. Cold Leg temperature (Wide APR1400 DCD.

Leg Temperature Range)

4. Reactor Coolant System 4. Reactor Coolant System Pressure (wide range) Pressure
5. Reactor Vessel Water Level 5. Reactor Vessel Level (RV Closure Head Level/RV Plenum Level)
6. Containment Sump Water Level 6. Reactor Cavity Level (wide range)
7. Containment Pressure (wide 7. Containment Pressure (Wide range) Range)
8. Penetration Flow Path 8. Containment Pressure KEPCO & KHNP 82

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Containment Isolation Valve (Extended Wide Range) Position 9. Containment Isolation Valve

9. Containment Area Radiation Position (high range) 10. Containment Upper Operating Area Radiation
10. Pressurizer Level 11. Pressurizer Level
11. Steam Generator Water Level 12. Steam Generator Level (Wide (wide range) Range)
12. Condensate Storage Tank 13. Holdup Volume Tank Level Level 14. Core Exit Temperature -
13. Core Exit Temperature - Quadrant 1 Quadrant [1] 15. Core Exit Temperature -
14. Core Exit Temperature - Quadrant 2 Quadrant [2] 16. Core Exit Temperature -
15. Core Exit Temperature - Quadrant 3 Quadrant [3] 17. Core Exit Temperature -
16. Core Exit Temperature - Quadrant 4 Quadrant [4] 18. Steam Generator Pressure
17. Emergency Feedwater Flow 19. RCS Saturation Margin
20. Core Exit Temperature Saturation Margin
21. Reactor Vessel Upper Head Saturation Margin
22. Pressurizer Pressure (Wide Range)
23. In-containment Refueling Water Storage Tank (IRWST) Level
24. IRWST Temperature
25. Containment Water Level
26. Containment Operating Area Radiation (For Fuel Handling Accident)
27. Spent Fuel Pool Radiation
28. Safety Injection Pump (SIP)

Direct Vessel Injection (DVI) Flow Rate KEPCO & KHNP 83

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

29. Main Steam Atmospheric Steam Dump Valve Position
30. Auxiliary Feedwater Flow
31. Hydrogen Concentration
32. Containment Atmosphere Temperature
33. 4.16 kV Switchgear Voltage
34. DC Bus Voltage
35. Instrument Power Bus Voltage 3.3.12 Remote LCO 3.3.12 LCO 3.3.12 The deviations reflect APR1400 Tier 2, 7.5.1.1 Shutdown The Remote Shutdown System The Remote Shutdown Display and design feature.

System Functions shall be OPERABLE. Control Functions in Table 3.3.12-1 shall be OPERABLE. Table 3.3.12-1 is added to describe the list for Remote Shutdown Display and Control in APR1400. ACTION ACTION Added a Note "LCO 3.0.4 is not

                         --------------NOTE--------------      --------------NOTES--------------     applicable" so as not to prohibit Separate Condition entry is allowed   1. LCO 3.0.4 is not applicable        or hinder operator to enter the for each Function.                    2. Separate Condition entry is        other MODES or other specified
                         -------------------------------------     allowed for each Function.        condition during safe shutdown
                                                               ------------------------------------- executing the unsatisfied required action based on the referenced plants.

SURVEILLANCE SURVEILLANCE Changed SR 3.3.12.2 SR 3.3.12.2 instrument channel Verify each required control circuit Verify that the required indication, to measurement and transfer switch is capable of control circuit, and transfer switch channel. performing the intended function. is capable of performing the intended function. SR 3.3.12.4 SR 3.3.12.4 [Perform CHANNEL FUNCTIONAL Perform CHANNEL FUNCTIONAL TEST of the reactor trip circuit TEST of reactor trip switch gear breaker open/closed indication. open/closed indication. KEPCO & KHNP 84

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) None Table 3.3.12-1 Table 3.3.12-1 is added to describe the list for Remote Shutdown Display and Control in APR1400. 3.3.13 [Logarithmic] - Same as NUREG-1432 Power Monitoring Channels Addition None LCO 3.3.14 The OPERABILITY of BDAS Related ACTIONS

 - Boron Dilution Alarms                                 Two Boron Dilution Alarm System      channels is necessary to meet     and (BDAS) channels shall be             the assumptions of the safety     SURVEILLANCE OPERABLE.                            analyses as described in the      REQUIREMENTS APR1400 DCD Tier 2, Section       are added.

15.4.6. APPLICABILITY MODE 3 within 1 hour after the neutron flux is within the startup range following a reactor shutdown, MODES 4 and 5. 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 RCS Pressure, LCO 3.4.1 LCO 3.4.1 The RCS DNB parameters are APR1400 specific Temperature, and RCS DNB parameters for RCS departure from nucleate the APR1400 plant specific value used Flow [Departure pressurizer pressure, cold leg boiling (DNB) parameters for values. (DCD 15.0.3) from Nucleate temperature, and RCS total flow pressurizer pressure, cold leg Boiling (DNB)] rate shall be within the limits temperature (Tcold), and RCS total LCO is to maintain the operation Limits specified in the COLR. flow rate shall be within the limits data within data specified in DCD specified below. Table 15.0-3.

a. Pressurizer pressure 154.7 2

kg/cm A (2,201 psia) and 2 161.6 kg/cm A (2,299 psia);

b. Tcold 286.7°C (548°F) and 293.3°C (560°F) for KEPCO & KHNP 85

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) THERMAL POWER < 90% RTP

c. Tcold 289.4°C (553°F) and 293.3°C (560°F) for THERMAL POWER 90%

RTP; and

d. RCS total flow rate 75.6E6 kg/hr (166.6E6 lb/hr).

APPLICABILITY APPLICABILITY Core power as an initial condition APR1400 specific MODE 1 MODES 1 and 2 for pressurizer of safety analyses for APR1400 value used

                         -----------------NOTE-----------------       pressure,                                is specified in DCD Table 15.0-3.  (DCD 15.0.3)

Pressurizer pressure limit does not MODE 1 for Tcold, MODE 2 includes the core power apply during: MODE 2 with keff 1.0 for Tcold, of 0%.

a. THERMAL POWER ramp > 5% MODE 1 for RCS total flow rate.

RTP per minute or -----------------NOTE-----------------

b. THERMAL POWER step > 10% Pressurizer pressure limit in RTP. MODE 1 does not apply during:
                         ------------------------------------------ a. THERMAL POWER ramp > 5%

RTP per minute or

b. THERMAL POWER step > 10%

RTP. CONDITION CONDITION LCO for RCS flow rate is only A. Pressurizer Pressure or RCS A. RCS total flow rate not within applied to MODE 1 in flow rate not within limits. limits. APPLICABILITY. So, the condition for the flow rate is separated from the pressurizer (PZR) pressure. C. RCS cold leg temperature not C. Pressurizer pressure or RCS LCOs for PZR pressure and cold within limits. Tcold not within limit. leg temperature are applied to MODES 1 and 2 in APPLICABILITY. So, PZR pressure is merged into the cold leg temperature. When the LCOs are not met, the condition shall be changed into the KEPCO & KHNP 86

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) not-applicable MODE. REQUIRED ACTION REQUIRED ACTION LCO 3.4.1 is applicable to A.1 Restore parameter(s) to within A.1 Restore RCS total flow rate to MODEs 1 & 2. If LCO 3.4.1 is not limit. within limits. met, plant condition shall not be C.1 Restore cold leg temperature C.1 Restore parameter(s) to within in MODEs 1 & 2. to within limits. limit. D.1 Reduce THERMAL POWER to D.1 Be in MODE 3. [30]% RTP. SURVEILLANCE SURVEILLANCE See II.4 APR1400 specific SR 3.4.1.1 Verify pressurizer SR 3.4.1.1 Verify pressurizer value used 2 pressure is within the limits pressure 154.7 kg/cm A specified in the COLR. (2,201 psia) and 2 161.6 kg/cm A (2,299 psia). SR 3.4.1.2 Verify RCS cold leg SR 3.4.1.2 Verify RCS Tcold APR1400 specific temperature is within the limits 286.7°C (548°F) and 293.3°C value used specified in the COLR. (560°F) for < 90% RTP or 289.4°C (553°F) and 293.3°C (560°F) for 90% RTP. SR 3.4.1.3 SR 3.4.1.3 APR1400 specific

                         -----------------NOTE-----------------     Verify RCS total flow rate  75.6E6                                          value used Only required to be met in MODE 1.         kg/hr (166.6E6 lb/hr)

Verify RCS total flow rate is greater than or equal to the limits specified in the COLR. SR 3.4.1.4 SR 3.4.1.4 Higher power is desirable for Current TS value

                         -----------------NOTE-----------------     -----------------NOTE-----------------     more accurate measurements        used Not required to be performed until         Not required to be performed until

[24] hours after [90]% RTP. 24 hours after 95% RTP. Verify by precision heat balance Verify by precision heat balance that RCS total flow rate is within that RCS total flow rate limits specified in the COLR. 75.6E6 kg/hr (166.6E6 lb/hr). KEPCO & KHNP 87

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.4.2 RCS Minimum LCO 3.4.2 LCO 3.4.2 See II.3.1 Temperature for Each RCS loop average Each RCS cold leg temperature Criticality temperature (Tavg) shall be [520]°F. (Tcold) shall be 286.7°C (548°F). APPLICABILITY APPLICABILITY See II.3.1 MODE 1 with Tavg in one or more MODE 1, RCS loops < [535]°F, MODE 2 with keff 1.0. MODE 2 with Tavg in one or more RCS loops < [535]°F and Keff 1.0. CONDITION CONDITION To enter a MODE out of A. Tavg in one or more RCS A. RCS Tcold in one or more RCS APPLICABILITY loops not within limit. loops not within limit. REQUIRED ACTION REQUIRED ACTION A.1 Be in MODE 2 with Keff < 1.0. A.1 Be in MODE 3. SURVEILLANCE SURVEILLANCE The first FREQUENCY is to RITS not applied. SR 3.4.2.1 Verify RCS Tavg in each SR 3.4.2.1 Verify RCS Tcold in each verify LCO more vigilantly when loop [520]°F. loop is 286.7°C (548°F). approaching core critical. The second FREQUENCY of 30 FREQUENCY FREQUENCY minutes is to reduce possibility of SR 3.4.2.1 [ 12 hours SR 3.4.2.1 Once within 15 minutes inadvertent violation of LCO by prior to achieving criticality frequent surveillance when the OR reactor is critical. AND In accordance with the Surveillance Frequency Control Program ] 30 minutes with the reactor critical and Tcold < 289.4°C 12 hour is added for consistency (553°F). with STS. AND 12 hours 3.4.3 RCS Pressure and REQUIRED ACTION REQUIRED ACTION Temperature (P/T) B.2. Be in MODE 5 with RCS B.2. Be in MODE 5 with RCS 2 Limits pressure < [500] psig. pressure < 33.7 kg/cm A (479 psia). KEPCO & KHNP 88

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.4.4 RCS Loops - LCO 3.4.4 LCO 3.4.4 More specific information is MODES 1 and 2 Two RCS loops shall be Two RCS loops shall be described for "in operation". OPERABLE and in operation. OPERABLE and in operation with two reactor coolant pumps operating in each loop. 3.4.5 RCS Loops - CONDITION C CONDITION C The meaning of the CONDITION MODE 3 Two RCS loops inoperable. No RCS loop OPERABLE. C is practically the same. REQUIRED ACTION REQUIRED ACTION The meaning of the REQUIRED C.1. Suspend operations that C.1. Suspend all operations that ACTION is practically the same. would cause introduction of would cause reduction of the coolant into the RCS with boron RCS boron concentration below concentration less than required that required to meet the SDM to meet SDM of LCO 3.1.1. of LCO 3.1.1. SURVEILLANCE SURVEILLANCE SR 3.4.5.1 Verify one RCS loop is SR 3.4.5.1 Verify required RCS in operation. loop is in operation. SR 3.4.5.2 Verify secondary side SR 3.4.5.2 Verify secondary side water level in each steam water level in each steam generator [25]%. generator 25% wide range indications. KEPCO & KHNP 89

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.4.6 RCS Loops - LCO 3.4.6 LCO 3.4.6 The LTOP analyses in FSAR There is no PZR MODE 4 -----------------NOTE----------------- -----------------NOTE----------------- Section 5.2.2.10 is performed level limit

2. No RCP shall be started with any 2. No RCP shall be started with any with the pressurizer in a water for RCP operation RCS cold leg temperature less RCS cold leg temperatures less solid condition with a since LTOP than or equal to the LTOP than or equal to the Low temperature difference of analysis assumes enable temperature specified in Temperature Overpressure 139°C (250°F) between RCS the PZR is the PTLR unless: Protection (LTOP) enable cold leg and secondary side in filled solid. Thus, temperature specified in the each steam generator. There the level limit is
a. Pressurizer water level is PTLR, unless secondary side are no analyses performed with eliminated.
                                  < [60]% or                            water temperature in each              the pressurizer at a lower water
b. Secondary side water steam generator (SG) is level. Therefore, the option in temperature in each steam < 55.6°C (100°F) above each of NUREG-1432 is not utilized and generator (SG) is < [100]°F the RCS cold leg temperatures. this is conservative and above each of the RCS cold ------------------------------------------ consistent with the analyses.

leg temperatures. CONDITION CONDITION LCO requires that two RCS A. One required loop inoperable. A. One required RCS loop loops or two SC trains are inoperable. operable and one loop or train is in operation. AND One RCS loop inoperable is not Two SC trains inoperable. LCO violation if another RCS loop and one of two SC trains are operable and any one of them is in operation. Therefore, combination for LCO violation is defined exactly. REQUIRED ACTION REQUIRED ACTION Natural circulation cooldown in A.2 None MODE 4 is not analyzed.

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

LCO 3.0.4.a is not applicable when entering MODE 4. KEPCO & KHNP 90

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Initiate action to make at least one steam generator available for decay heat removal via natural circulation. CONDITION CONDITION LCO requires that two RCS None B. One required SC train loops or SC trains are operable inoperable. and one loop or train is in operation. AND This condition is for defining Two required RCS loops combination for LCO violation inoperable. exactly. REQUIRED ACTION REQUIRED ACTION LCO requires that two RCS None B.1 Be in MODE 5. loops or SC trains are operable and one loop or train is in operation. This condition is for defining combination for LCO violation exactly. With only one SC train OPERABLE, redundancy for decay heat removal is lost and then, in the event of a loss of the remaining SC train, it would be safer to be in MODE 5 rather than MODE 4. CONDITION CONDITION The meanings of the conditions B. Two required loops or trains C. Two required RCS loops or SC are practically the same. inoperable. trains inoperable OR OR Required loop or train not in Required RCS loop or SC train operation. not in operation. KEPCO & KHNP 91

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION B.1 Suspend operations that would C.1 Suspend all operations that cause introduction of coolant would cause reduction of the into the RCS with boron RCS boron concentration concentration less than below that required to meet required to meet SDM of the SDM of LCO 3.1.1. LCO 3.1.1. SURVEILLANCE SURVEILLANCE The meaning of the Surveillance SR 3.4.6.1 SR 3.4.6.1 Requirement is practically the Verify required RCS loop or SDC Verify one RCS loop or SC train is same. train is in operation. in operation SR 3.4.6.2 SR 3.4.6.2 Verify secondary side water level in Verify secondary side water level in required SG(s) is [25]%. required SG(s) is 25% wide range indication. SR 3.4.6.4 SR 3.4.6.4 TSTF-523 (Managing Gas None ------------NOTE ------------------ Accumulation) is applied to Not required to be performed until APR1400 Technical 12 hours after entering MODE 4. Specifications. Verify required SC train locations susceptible to gas accumulation are sufficiently filled with water. FREQUENCY 31 days 3.4.7 RCS Loops - LCO 3.4.7 LCO 3.4.7 MODE 5, Loops b. The secondary side water level b. The secondary side water level Filled of each steam generator SG shall of each steam generator (SG) shall be 25%. be 25% wide range indication.

                         -----------------NOTE----------------- -----------------NOTE-----------------
1. The SDC pump of the train in 1. The SC pump of the train in operation may be removed from operation may be removed from operation for 1 hour per 8 hour operation for 1 hour per 8 hour period provided: period provided:

KEPCO & KHNP 92

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

a. No operations are permitted a. No operations are permitted that would cause introduction that would cause introduction of coolant into the RCS with of coolant into the RCS with boron concentration less than boron concentration less required to meet the SDM of than that required to meet LCO 3.1.1 and the SDM of LCO 3.1.1; and LCO 3.4.7 LCO 3.4.7
                         -----------------NOTE----------------- -----------------NOTE-----------------     The LTOP analyses in FSAR Section 5.2.2.10 is performed
3. No reactor coolant pump (RCP) 3. No reactor coolant pump (RCP) with the pressurizer in a water shall be started with any RCS shall be started with one or solid condition with a cold leg temperature less than more of the RCS cold leg temperature difference of or equal to the LTOP enable temperatures less than or equal 139°C (250°F) between RCS temperature specified in the to the Low Temperature cold leg and secondary side in PTLR unless: Overpressure Protection each steam generator. There (LTOP) enable temperature are no analyses performed with
a. Pressurizer water level is specified in the PTLR, unless the pressurizer at a lower water
                             < [60]% or                             secondary water temperature of         level. Therefore, the option in each SG is < 55.6°C (100°F)            NUREG-1432 is not utilized and
b. The secondary side water above each of the RCS cold leg this is conservative and temperature in each SG is temperatures. consistent with the analyses.
                             < [100]°F above each of the RCS cold leg temperatures.         4. All SC trains may be removed from operation during planned
4. All SDC trains may not be in heatup to MODE 4 when at least operation during planned one RCS loop is in operation.

heatup to MODE 4 when at least one RCS loop is in operation. LCO 3.4.7 LCO 3.4.7 See III.5.2.1. None -----------------NOTE-----------------

5. A containment spray pump can be manually realigned to meet the requirement of a SC pump.

REQUIRED ACTION REQUIRED ACTION C.1 Suspend operations that would C.1 Suspend all operations cause introduction of coolant into involving reduction in RCS boron KEPCO & KHNP 93

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) the RCS with boron concentration concentration. less than required to meet SDM of LCO 3.1.1. SURVEILLANCE SURVEILLANCE SR 3.4.7.1 SR 3.4.7.1 Verify required SDC train is in Verify one SC train is in operation operation. with circulating reactor coolant at a flow rate of 15,710 L/min (4,150 gpm). SR 3.4.7.2 SR 3.4.7.2 Verify required SG secondary side Verify required SG secondary side water level is [25]%. water level 25% wide range indication. None SR 3.4.7.4 TSTF-523 (Managing Gas Verify required SC train locations Accumulation) is applied to susceptible to gas accumulation APR1400 Technical are sufficiently filled with water. Specifications. FREQUENCY 31 days 3.4.8 RCS Loops - LCO 3.4.8 LCO 3.4.8 MODE 5, Loops Two shutdown cooling (SDC) The heat removal system shall be Not Filled trains shall be OPERABLE and in the following status: one SDC train shall be in operation. a. Two shutdown cooling (SC) trains shall be OPERABLE and one SC train shall be in operation; and

b. The containment spray pump in the same electrical division as the operating SC train shall be OPERABLE.

None. -----------------NOTE----------------- See III.5.2.1

3. The containment spray pump in the same electrical division as the KEPCO & KHNP 94

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SC train in operation may be manually aligned to meet the requirements of its associated SC pump.

4. Operation in the mid-loop condition (RCS level 36.30 m (119 ft 1 in)) is allowed if the time after reactor shutdown is 96 hours and core exit temperature is maintained 57.2°C (135°F).

CONDITION CONDITION The meanings of the B. No Required SDC train B. Two SC trains inoperable. CONDITION are practically the OPERABLE. same. OR OR No SC train in operation. Required SDC train not in operation. None C. Containment Spray pump in the same electrical division as the operating SC train inoperable. D. Required Action and associated Completion Time of Required Action C.3 not met. E. Core exit temperature > 57.2°C (135°F) during mid-loop operation. OR RCS level 36.30 m (119 ft 1 in) with < 96 hours after reactor shutdown. KEPCO & KHNP 95

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION If shutdown cooling pump cannot None AND be restored, RCS level should be B.3 Initiate action to raise RCS raised. This will place the plant in level to > 38.72 m (127 ft 1/4 a conservative position with in). respective to decay heat removal. None C.1 If the containment spray pump in the same electrical division as the alternate SC train is OPERABLE, initiate action to place the alternate SC train in operation. AND C.2 Monitor SC System performance. AND C.3 Restore containment spray pump to OPERABLE status. None D.1 Raise RCS level > 38.72 m (127 ft 1/4 in). None E.1 Initiate action to restore core exit temperature to 57.2°C (135°F). AND E.2 Initiate action to raise RCS level above mid-loop condition (> 36.30 m (119 ft 1 in)). KEPCO & KHNP 96

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE None SR 3.4.8.1

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

Only required to be met when in mid-loop operation. Verify core exit temperature is 57.2°C (135°F). FREQUENCY 15 minutes SR 3.4.8.1 SR 3.4.8.2 Verify required SDC train is in Verify one SC train is in operation operation. with circulating reactor coolant at a flow rate of 14,385 L/min (3,800 gpm) and < 15,710 L/min (4,150 gpm). SR 3.4.8.2 SR 3.4.8.3 Verify correct breaker alignment Verify correct breaker alignment and indicated power available to and indicated power available to each required SDC pump. the required SC pump. None SR 3.4.8.4 Verify correct breaker alignment and indicated power available to the required containment spray pump that is not in operation. FREQUENCY 24 hours None SR 3.4.8.5 TSTF-523 (Managing Gas Verify required SC train locations Accumulation) is applied to susceptible to gas accumulation APR1400 Technical are sufficiently filled with water. Specifications. FREQUENCY 31 days KEPCO & KHNP 97

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.4.9 Pressurizer LCO 3.4.9 LCO 3.4.9 The pressurizer water level of APR1400 specific

a. Pressurizer water level < [60]% a. Pressurizer water level 25% 25% is determined by value used and and 56%, and considering the water level to
b. [Two groups of] pressurizer b. Two groups of pressurizer prevent heater's burn-up from heaters OPERABLE with the backup heaters OPERABLE with low water level. The pressurizer capacity [of each group] [150 kW the capacity of each group 200 water level of 56% is to provide

[and capable of being powered kW and capable of being powered steam space for controlling from an emergency power supply]. from an emergency power supply. pressurizer pressure. Heater capacity is determined by considering heat loss from pressurizer insulation. The value of 200 kW is sufficient to add heat for controlling pressurizer pressure for APR1400. CONDITION CONDITION The deviations reflect the None. B. Required Action and associated APR1400 plant specific Completion Time of Condition A operating practice. not met. B. One [required] group of C. One required group of pressurizer heaters inoperable. pressurizer backup heaters inoperable. C. Required Action and associated D. Required Action and associated Completion Time of Condition B Completion Time of Condition C not met. not met. REQUIRED ACTION REQUIRED ACTION The deviations reflect the None. A.1 Restore pressurizer water level APR1400 plant specific within limit. operating practice. With PZR water level outside the COMPLETION TIME limits, ACTION is taken within 1 1 hour hour to restore the plant to be operated within the bounds of the safety analyses. If PZR water level cannot be restored to within the limits in 1 hour, the plant is KEPCO & KHNP 98

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) placed in MODES 3 with the reactor trip circuit breakers open within 6 hours, and in MODE 4 within 12 hours. A.1 Be in MODE 3 with reactor trip B.1 Be in MODE 3 with reactor trip The deviations reflect the breakers open. switch gears open. APR1400 plant specific operating practice. AND AND With PZR water level outside the limits, ACTION is taken within 1 A.2 Be in MODE 4. B.2 Be in MODE 4. hour to restore the plant to be operated within the bounds of the safety analyses. If PZR water level cannot be restored to within the limits in 1 hour, the plant is placed in MODES 3 with the reactor trip circuit breakers open within 6 hours, and in MODE 4 within 12 hours. B.1 Restore [required] group of C.1 Restore required group of pressurizer heaters to pressurizer backup heaters to OPERABLE status. OPERABLE status. C.1 Be in MODE 3. D.1 Be in MODE 3. AND AND C.2 Be in MODE 4. D.2 Be in MODE 4. SURVEILLANCE SURVEILLANCE SR 3.4.9.1 SR 3.4.9.1 Verify pressurizer water level is Verify pressurizer water level

                         < [60]%.                             25% and  56%.
                         ----------REVIEWERS NOTE---------

The frequency for performing pressurizer heater capacity testing shall be either 18 months or 92 KEPCO & KHNP 99

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) days, depending on whether or not the plant has dedicated safety-related heaters. For dedicated safety-related heaters, which do not normally operate, 92 days is applied. For nondedicated safety-related heaters, which normally operate, 18 months is applied. SR 3.4.9.2 Verify capacity of each SR 3.4.9.2 Verify capacity of each required group of pressurizer required group of pressurizer heaters [150] kW. backup heaters 200 kW. SR 3.4.9.3 [ Verify required SR 3.4.9.3 Verify that on an APR1400 pressurizer backup pressurizer heaters are capable of engineered safety features heaters can be manually being powered from an emergency actuation test signal concurrent transferred to be energized by power supply. with a loss of offsite power: emergency power supply.

a. Pressurizer backup heaters are automatically shed from emergency power sources.
b. Pressurizer backup heaters can be reconnected to their respective buses manually from the control room.

3.4.10 Pressurizer LCO 3.4.10 LCO 3.4.10 The setpoint range is a APR1400 Safety Valves [Two] pressurizer safety valves Four pressurizer POSRVs shall be specific characteristic and the shall be OPERABLE with lift OPERABLE such that: valve type is different. settings [2475] psia and [2525] a. Two spring-loaded pilot valves psia. shall be OPERABLE with lift Pressurizer Pilot Operated 2 settings 171.1 kg/cm A Safety Relief Valve (POSRV) is (2,433 psia) and 176.3 applied in APR1400. 2 kg/cm A (2,507 psia).

b. The opening time of pressurizer The opening time is specified in POSRV shall be 0.5 seconds, the Design Specification and including dead time. verified by test for APR1400 KEPCO & KHNP 100

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) plant. APPLICABILITY APPLICABILITY The meanings of the

                         -----------------NOTE----------------- -----------------NOTE----------------- APPLICABILITY are practically The lift settings are not required to  The opening time measurement           the same. The 72 hours be within LCO limits during            and lift pressure setting of each      exception is based on 18 hours MODES 3 and 4 for the purpose of       POSRV are not required to be           outage time for each of the four setting the pressurizer safety         within LCO limits during MODES 3       valves (APR1400 adapts 4 valves under ambient (hot)             and 4 for the purpose of setting the   POSRVs). The 18 hours period conditions. This exception is          POSRVs under ambient (hot)             is determined based on allowed for [36] hours following       conditions. This exception is          operating experience.

entry into MODE 3 provided a allowed for 72 hours following entry preliminary cold setting was made into MODE 3 provided a See III.2.2.2 prior to heatup preliminary cold setting was made prior to heatup. REQUIRED ACTION REQUIRED ACTION The REQUIRED ACTIONs B.2 Be in MODE 4 with any RCS B.2.1 Be in MODE 4 with all RCS reflect the APR1400 design. cold leg temperature less than cold leg temperatures less When the POSRV(s) are or equal to the LTOP enable than or equal to LTOP inoperable, LTOP relief valves temperature specified in the enable temperature shall be aligned for OPP. PTLR. specified in PTLR. Alignment of LTOP relief valves can be allowed by meeting OR conditions by reducing the cold leg temperature down to the B.2.2 Be in MODE 4 on shutdown LTOP enable temperature and cooling with requirements by opening SCS isolation valves. of LCO 3.4.11 met. SURVEILLANCE SURVEILLANCE The SRs reflect POSRV SR 3.4.10.1 Verify each SR 3.4.10.1 Verify open and close characteristics. pressurizer safety valve is positions for the following OPERABLE in accordance valves in the main control room The testing and inspection for with the inservice Testing (MCR): POSRVs are given in DCD Program. Following testing, lift Section 5.2.2.10. settings shall be within +/-1%. a. Main valves - close,

b. Motor-operated isolation valves and manual isolation KEPCO & KHNP 101

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) valves - open,

c. Spring-loaded pilot valves -

close, and

d. Motor-operated pilot valves
                                                                 - close.

None SR 3.4.10.2 Verify electric power disconnections of the following motor-operated valves:

a. Motor-operated isolation valves and
b. Upstream valve of motor-operated pilot valves.

None SR 3.4.10.3 For each pressurizer POSRV:

a. Verify lift pressure settings of each of the two spring-loaded pilot valves 2

are set 171.1 kg/cm A (2,433 psia) and 2 176.3 kg/cm A (2,507 psia).

b. Adjust each spring-loaded pilot valve, as necessary, so that the lift pressure 2

setting is 172.4 kg/cm A (2,451.4 psia) and 2 175.0 kg/cm A (2,488.5 psia).

c. Verify opening time of pressurizer POSRV is 0.5 seconds, including dead time.

None SR 3.4.10.4 Verify alarm devices for valve positions and electric power connections of the following valves: KEPCO & KHNP 102

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

a. Motor-operated isolation valves - power connection alarm,
b. Upstream valve of motor-operated pilot valves
                                                                    - power connection alarm, and
c. Manual isolation valves -

not fully open alarm. None SR 3.4.10.5 Verify position indicators of the following valves are operated normally:

a. Main valves,
b. Spring-loaded pilot valves,
c. Motor-operated pilot valves, and
d. Motor-operated isolation valves and manual isolation valves.

None SR 3.4.10.6 Verify downstream manual valves of spring-loaded pilot valves are locked in open position. 3.4.11 Pressurizer The LCO is for PORV. None There is no PORV in APR1400 Power Operated (plant specific). Relief Valves (PORVs) 3.4.12 Low Temperature LCO 3.4.12 LCO 3.4.11 See III.5.2.2 Overpressure An LTOP System shall be LTOP System shall be OPERABLE Protection OPERABLE with a maximum of as follows: (LTOP) System one high pressure safety injection (HPSI) pump and one charging pump capable of injecting into the RCS and the safety injection tanks KEPCO & KHNP 103

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) (SITs) isolated, and:

                         ---------------NOTES---------------
1. [Two charging pumps] may be made capable of injecting for 1 hour for pump swap operations.
2. SIT may be unisolated when SIT pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR.
a. Two OPERABLE power a. Two OPERABLE Shutdown operated relief valves (PORVs) Cooling System (SCS) suction with lift settings within the limits line relief valves with lift settings specified in the PTLR or specified in the PTLR, or
b. The RCS depressurized and an b. RCS depressurized and an RCS 2 2 RCS vent of [1.3] square vent of 180.6 cm (28 in )

inches. established. ACTIONS ACTIONS See III.5.2.2

                         ---------------NOTE----------------       None LCO 3.0.4.b is not applicable to PORVs when entering MODE 4.

CONDITION CONDITION See III.5.2.2 A. Two or more HPSI pumps None capable of injecting into the RCS. B. Two or more charging pumps None See III.5.2.2 capable of injecting into the RCS. KEPCO & KHNP 104

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) C. A SIT not isolated when SIT None See III.5.2.2 pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR. D. Required Action and associated None See III.5.2.2 Completion Time of Time of Condition C not met. E. One required PORV inoperable A. One required SCS suction line Different valve name is used for in MODE 4. relief valve inoperable in MODE 4. APR1400. F. One required PORV inoperable B. One required SCS suction line Different valve name is used for in MODE 5 or 6. relief valve inoperable in MODE APR1400. 5 or 6. G. Two required PORVs C. Required Action and associated C. When one SCS suction inoperable. Completion Time of Condition A isolation valve is inoperable or B not met. and the required action and OR associated completion time D. Two required SCS suction line are not met in ACTION A or Required Action and associated relief valves inoperable. B, an additional action for Completion Time of Condition preventing RCS A, [B], D, E, or F not met. pressurization should be taken such as establishing a OR vent. LTOP System inoperable for D. If two LTOP relief valves are any reason other than Condition inoperable, an action for A, [B], C, D, E, or F. preventing RCS pressurization should be taken such as establishing a vent immediately. Different valve name is used in APR1400. KEPCO & KHNP 105

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE SR 3.4.12.1 Verify a maximum of None See III.5.2.2 one HPSI pump is capable of injecting into the RCS. SR 3.4.12.2 Verify a maximum of None one charging pump is capable of injecting into the RCS. SR 3.4.12.3 Verify each SIT None isolated. SR 3.4.12.4 Verify required RCS SR 3.4.11.1 RCS vent path is not required vent [1.3] square inches is -----------------NOTE----------------- because LTOP relief valve open. Only required to be met when setpoint is already adjusted for complying with LCO 3.4.11.a. overpressure protection. Verify both SCS suction isolation valves in both SCS suction flow paths are open. SR 3.4.11.2

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

Only required to be met when complying with LCO 3.4.11.b. 2 Verify RCS vent of 180.6 cm 2 (28 in ) is established. SR 3.4.12.5 Verify PORV block None During MODE 4~6, at least one valve is open for each required SC train shall be in operation. PORV. Therefore SCS suction line isolation valves (PORV block valves) are open. SR 3.4.12.6 None LTOP relief valves are not a

                         -----------------NOTE-----------------                                           PORV but self-actuating type.

Not required to be performed until Therefore this SR is not required. [12] hours after decreasing RCS cold leg temperature to less than or equal to the LTOP enable KEPCO & KHNP 106

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) temperature specified in the PTLR. Perform CHANNEL FUNCTIONAL TEST on each required PORV, excluding actuation. SR 3.4.12.7 Perform CHANNEL SR 3.4.11.3 LTOP relief valves are not a CALIBRATION on each -----------------NOTE----------------- PORV but self-actuating type. required PORV actuation Only required to be met when Therefore this SR is not required channel. complying with LCO 3.4.11.a. to prevent RCS

                                                                    ------------------------------------------ over-pressurization.

Verify the lift setting for each required SCS suction line relief valve is within limits. 3.4.13 RCS Operational - Same as NUREG-1432 3.4.12 for LEAKAGE APR1400. 3.4.14 RCS Pressure APPLICABILITY APPLICABILITY 3.4.13 for Isolation Valve MODE 4, except valves in the MODE 4, except valves in the APR1400. (PIV) Leakage shutdown cooling (SDC) flow path shutdown cooling (SC) flow paths when in, or during the transition to when in SC operation or during the or from, the SDC mode of transition to or from SC operation. operation REQUIRED ACTION REQUIRED ACTION An isolation may cause a loss of

                         -----------------NOTE-----------------     -----------------NOTE-----------------     Residual Heat Removal (RHR).

Each valve used to satisfy Each valve used to satisfy The (automatic) isolation Required Action A.1 and Required Required Actions A.1 and A.2 must function is not used in APR1400. Action A.2 must have been verified have been verified to meet the to meet SR 3.4.14.1 and be on the Surveillance and Frequency of SR RCS pressure boundary [or the 3.4.13.1 and be on the reactor high pressure portion of the coolant pressure boundary. system]. ------------------------------------------ A.2 [Isolate the high pressure A.2 portion of the affected system from the low pressure portion by use of a second closed KEPCO & KHNP 107

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) manual, deactivated automatic, or check valve. [or] Restore RCS PIV to within Restore RCS PIV leakage to limits. within limit. CONDITION CONDITION There is no auto-closure C. Shutdown Cooling (SDC) C. SC System open permissive interlock in APR1400. OPP for System autoclosure interlock interlock function inoperable. SCS is performed by LTOP relief function inoperable. valves. REQUIRED ACTION REQUIRED ACTION An isolation may cause a loss of C.1 Isolate the affected penetration C.1 Depressurize RCS pressure RHR. Therefore RCS should be by use of one closed manual below open permissive depressurized for connecting or deactivated automatic interlock setpoint. SCS operation for residual heat valve. removal. SURVEILLANCE SURVEILLANCE SR 3.4.14.1 SR 3.4.13.1 Verify leakage from each RCS PIV Verify leakage from each RCS PIV is equivalent to 0.5 gpm per is equivalent to 1.89 L/min nominal inch of valve size up to a (0.5 gpm) per nominal 2.54 cm maximum of 5 gpm at an RCS (1 in) of valve size up to a pressure [2215] psia and [2255] maximum of 18.9 L/min (5 gpm) at 2 psia. an RCS pressure 156.8 kg/cm A 2 (2,230 psia) and 159.6 kg/cm A (2,270 psia). FREQUENCY FREQUENCY The valve leakage rate shall be SR 3.4.14.1 In accordance with the SR 3.4.13.1 18 months verified for in-service after any Inservice Testing Program, maintenance, repair or and [[18] months replacement work. AND AND Prior to entering MODE 2 Prior to entering MODE 2 determine the unit has been in whenever unit has been in KEPCO & KHNP 108

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) MODE 5 for 7 days or more, if MODE 5 for 72 hours or more, if leakage testing has not been leakage testing has not been performed in the previous 9 performed in previous 9 months months AND Prior to returning valve to service following maintenance, repair, or replacement work on valve AND AND Within 24 hours following valve Within 24 hours following valve actuation due to automatic or actuation due to automatic or manual action or flow through manual action or flow through the valve the valve SURVEILLANCE SURVEILLANCE There is no auto closure interlock SR 3.4.14.2 SR 3.4.13.2 in APR1400.

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

[ Not required to be met when the Not required if SC suction line SDC System autoclosure interlock isolation valves are open for Low is disabled in accordance with SR Temperature Overpressure 3.4.12.7. Protection (LTOP) by LCO

                         ------------------------------------------ 3.4.11.a.

Verify SDC System autoclosure Verify SC system open permissive interlock prevents the valves from interlock prevents the SC system being opened with a simulated or suction line isolation valve from actual RCS pressure signal [425] being opened with a simulated or psig. actual RCS pressure signal 2 31.6 kg/cm A (450 psia). SR 3.4.14.3 None There is no auto closure interlock

                         -----------------NOTE-----------------                                                in APR1400.

KEPCO & KHNP 109

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) [ Not required to be met when the SDC System autoclosure interlock is disabled in accordance with SR 3.4.12.7. Verify SDC System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal [600] psig. 3.4.15 RCS Leakage LCO 3.4.15 LCO 3.4.14 1. For item 'a', Containment Detection [Two of] the following RCS leakage The following RCS leakage sump means containment Instrumentation detection instrumentation shall be detection instrumentation shall be sump level. Therefore they OPERABLE: OPERABLE: are the same.

a. One containment sump a. One containment sump 2. For item 'c', the method used monitor (level) monitor, in APR1400 is one of the
b. One containment atmosphere b. One containment atmosphere methods described in RG radioactivity monitor (gaseous radioactivity (particulate) 1.45 Rev. 1.

or particulate), and monitor, and

c. One containment air cooler c. One containment atmosphere condensate flow rate monitor.] humidity monitor.

CONDITION CONDITION A. Containment sump monitor A. Required containment sump inoperable. (level) monitor inoperable. B. Required containment B. Required containment atmosphere radioactivity atmosphere radioactivity monitor inoperable. (particulate) monitor inoperable. C. [ Containment air cooler C. Required containment condensate flow rate monitor atmosphere humidity monitor inoperable. inoperable.

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

Only applicable when the containment atmosphere gaseous radiation monitor is the only KEPCO & KHNP 110

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) OPERABLE monitor. D. Containment sump monitor D. Required containment sump inoperable. (level) monitor inoperable. AND AND [ Containment air cooler Required containment condensate flow rate monitor atmosphere humidity monitor inoperable. ] inoperable. E. [ Required containment E. Required containment atmosphere radioactivity atmosphere radioactivity monitor inoperable. (particulate) monitor inoperable. AND AND [ Containment air cooler Required containment condensate flow rate monitor atmosphere humidity monitor inoperable. ] inoperable. F. Required containment sump (level) monitor inoperable. AND Required containment atmosphere radioactivity (particulate) monitor inoperable. F. Required Action and associated G. Required Action and associated Completion Time not met. Completion Time not met. G. All required monitors inoperable. H. All required monitors inoperable. REQUIRED ACTION REQUIRED ACTION A.2 Restore containment sump A.2 Restore required containment monitor to OPERABLE status. sump (level) monitor to OPERABLE status. B.2.1 Restore required B.2 Restore required containment containment atmosphere atmosphere radioactivity radioactivity monitor to (particulate) monitor to OPERABLE status. OPERABLE status. OR KEPCO & KHNP 111

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) [ B.2.2 Verify containment air cooler condensate flow rate monitor is OPERABLE. C.1 Perform SR 3.4.15.1. C.1.1 Perform SR 3.4.14.1. OR OR C.2 ---------------NOTE-------------- C.1.2 ---------------NOTE-------------- Not required until 12 hours Not required until 12 hours after after establishment of establishment of steady state steady state operation. operation. Perform SR 3.4.13.1. Perform SR 3.4.12.1. AND C.2 Restore required containment atmosphere humidity monitor to OPERABLE status. D.1 Analyze grab samples of the containment atmosphere. AND D.2.1 Restore containment sump D.1 Restore required containment monitor to OPERABLE status. sump (level) monitor to OPERABLE status. OR OR [ D.2.2 Restore containment air D.2 Restore required containment cooler condensate flow rate atmosphere humidity monitor to monitor to OPERABLE status. ] OPERABLE status. KEPCO & KHNP 112

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) E.1 Restore required containment E.1 Restore required containment atmosphere radioactivity atmosphere radioactivity monitor to OPERABLE status. (particulate) monitor to OPERABLE status. OR OR E.2 Restore containment air cooler E.2 Restore required containment condensate flow rate monitor to atmosphere humidity monitor to OPERABLE status. OPERABLE status. None F.1 Restore required containment sump (level) monitor to OPERABLE status. OR F.2 Restore required containment atmosphere radioactivity (particulate) monitor to OPERABLE status. F.1 Be in MODE 3. G.1 Be in MODE 3. AND AND F.2 Be in MODE 5. G.2 Be in MODE 5. G.1 Enter LCO 3.0.3. H.1 Enter LCO 3.0.3. SURVEILLANCE SURVEILLANCE None 3.4.14.2 Perform CHANNEL CHECK of the required containment atmosphere humidity monitor. None 3.4.14.4 Perform CHANNEL FUNCTIONAL TEST of the required containment atmosphere humidity monitor None 3.4.14.7 KEPCO & KHNP 113

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Perform CHANNEL CALIBRATION of the required containment atmosphere humidity monitor. 3.4.16 RCS Specific LCO 3.4.16 LCO 3.4.15 See II.2.2 Activity The specific activity of the reactor The specific activity of the reactor coolant shall be within limits. coolant shall be limited to:

a. DOSE EQUIVALENT I-131 specific activity 3.7E4 Bq/g (1.0 µCi/g) and
b. DOSE EQUIVALENT XE-133 specific activity 1.11E7 Bq/g (297.3 µCi/g).

APPLICABILITY APPLICABILITY MODES 1 and 2, MODES 1, 2, 3 and 4. MODE 3 with RCS average temperature (Tavg) 500°F. CONDITION CONDITION See II.2.2 B. Required Action and associated B. DOSE EQUIVALENT XE-133 Completion Time of Condition A > 1.11E7 Bq/g (297.3 µCi/g). not met. OR DOSE EQUIVALENT I-131 in the unacceptable region of Figure 3.4.16-1. C. Required Action and associated C. Gross specific activity of the Completion Time of Condition A reactor coolant not within limit. or B not met. OR DOSE EQUIVALENT I-131

                                                                   > 2.22E6 Bq/g (60 µCi/g).

KEPCO & KHNP 114

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION In order to be consistent with

                         -----------------NOTE-----------------     -----------------NOTE-----------------     TSTF-490, Rev. 0, the relevant LCO 3.0.4.c is applicable.                 LCO 3.0.4 is not applicable.               phrases are modified.

A.1 Verify DOSE EQUIVALENT A.1 Verify DOSE EQUIVALENT I-131 within the acceptable I-131 2.22E6 Bq/g region of Figure 3.4.16-1. (60 µCi/g). AND AND A.2 Restore DOSE EQUIVALENT I-131 to within limit. A.2 Restore DOSE EQUIVALENT I-131 to within limit.

                                                                    -----------------NOTE-----------------     In order to be consistent with LCO 3.0.4 is not applicable.               TSTF-490, Rev. 0, the relevant
                                                                    ------------------------------------------ phrases are modified.

B.1 Be in MODE 3 with B.1 Restore DOSE EQUIVALENT - Related COMPLETION TIME Tavg < 500°F. XE-133 to within limit. is changed. C.1 Be in MODE 3 with C.1 Be in MODE 3. In order to be consistent with Tavg < 500°F. TSTF-490, Rev. 0, the relevant AND phrases are modified.

                                                                                                                - Related COMPLETION TIME C.2 Be in MODE 5.                             is changed.

SURVEILLANCE SURVEILLANCE In order to be consistent with the SR 3.4.16.1 SR 3.4.15.1 TSTF-490, Rev. 0, the contents

                                                                    -----------------NOTE-----------------     are modified.

Only required to be performed in MODE 1. Verify reactor coolant gross Verify reactor coolant DOSE specific activity 100/ Ci/gm. EQUIVALENT XE-133 specific activity 1.11E7 Bq/g (297.3 µCi/g). SR 3.4.16.3 None In order to be consistent with the

                         -----------------NOTE-----------------                                                TSTF-490, Rev. 0, this item is Not required to be performed until                                                    deleted.

KEPCO & KHNP 115

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 31 days after a minimum of 2 - The definition of is deleted in EFPD and 20 days of MODE 1 "1.1 Definitions". operation have elapsed since the reactor was last subcritical for 48 hours. Determine from a sample taken in MODE 1 after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for 48 hours. Figure 3.4.16-1 None In order to be consistent with TSTF-490, Rev. 0, the figure is deleted. Addition None LCO 3.4.16 BTP RSB 5-4 requires as Related ACTIONS

 - Reactor Coolant Gas                                              The following RCGV flow paths      follows:                             and Vent (RCGV)                                                      shall be OPERABLE:                 1. The design shall be such that     SURVEILLANCE Function                                                         a. Two flow paths from the reactor     the reactor can be taken from    REQUIREMENTS vessel closure head to the          normal operating conditions      are added.

in-containment refueling water to cold shutdown using only storage tank (IRWST), and safety-grade systems.

2. RCGVS is a safety-grade
b. Two flow paths from the means in order to use for pressurizer steam space to the pressure control during RCS IRWST. cooling from the hot zero power to the entry condition of APPLICABILITY SCS.

MODES 1,2 and 3, MODE 4 with Shutdown Cooling Therefore it is controlled by LCO (SC) System not aligned for Low for operability. Temperature Overpressure Protection (LTOP) of the reactor coolant pressure boundary (RCPB). KEPCO & KHNP 116

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.4.17 Special Test LCO 3.4.17 None These STEs are needed during a Exceptions The requirements of LCO 3.4.4, startup & PHYSICS TESTS in (STE)-RCS "RCS Loops - MODES 1 and 2," MODE 2 which means actually a Loops and the listed requirements of LCO Natural Circulation test at a 3.3.1, "Reactor Protective System criticality condition. APR1400 (RPS) Instrumentation - performs Natural Circulation test Operating," for the [(Analog) RC at Hot Standby condition, so flow low, thermal margin or low these STEs are not required. pressure, and asymmetric steam generator transient protective trip functions] [(Digital) high log power, high local power density, low departure from nucleate boiling ratio protective trip functions] may be suspended provided:

a. THERMAL POWER 5% RTP and
b. The reactor trip setpoints of the OPERABLE power level channels are set 20% RTP.

3.4.18 Steam Generator LCO 3.4.18 LCO 3.4.17 APR1400 does not have a repair (SG) Tube SG tube integrity shall be SG tube integrity shall be method approved by NRC. Integrity maintained. maintained. AND AND All SG tubes satisfying the tube All SG tubes satisfying the tube repair criteria shall be plugged [or plugging criteria shall be plugged in repaired] in accordance with the accordance with the Steam Steam Generator Program. Generator Program. CONDITION CONDITION A. One or more SG tubes satisfying A. One or more SG tubes satisfying the tube repair criteria and not the tube plugging criteria and plugged [or repaired] in not plugged in accordance with accordance with the Steam the Steam Generator Program. KEPCO & KHNP 117

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Generator Program. SURVEILLANCE SURVEILLANCE A. verify that each SG tube that A. Verify each inspected SG tube satisfies the tube repair criteria that satisfies tube plugging is plugged [or repaired] in criteria is plugged in accordance with the Steam accordance with Steam Generator Program. Generator Program. 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS) 3.5.1 Safety Injection APPLICABILITY APPLICABILITY See III.3.2.1 Tanks (SITs) MODES 1 and 2, MODES 1 and 2, MODE 3 with pressurizer pressure MODES 3 and 4 with pressurizer 2 [700] psia. pressure 50.3 kg/cm A (715 psia). CONDITION CONDITION Second part of A. One SIT inoperable due to A. One SIT inoperable due to condition added by boron concentration not within boron concentration not within RAI 496-8630, limits. limits. Question 6.03-10, Revision 2. OR OR One SIT inoperable due to One SIT inoperable due to the inability to verify water B-10 isotopic concentration level or pressure. not within limits. OR One SIT inoperable due to the inability to verify water level or pressure. REQUIRED ACTION REQUIRED ACTION C.2 C.2 See III.3.2.1 Reduce with pressurizer pressure Reduce pressurizer pressure to < 2 to < [700] psia. 50.3 kg/cm A (715 psia). KEPCO & KHNP 118

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) COMPLETION TIME COMPLETION TIME 12 hours from NUREG-1432 2 hours 12 hours Rev. 2 is used rather than 2 hours from NUREG-1432 Rev. 3, 4. According to the NUREG-1432 Rev 04 Bases, the 12 hr is used as a pressure reduction time. Therefore, it seems appropriate to use 12 hr rather than 2 hr. SURVEILLANCE SURVEILLANCE SR 3.5.1.2 SR 3.5.1.2 Verify borated water volume in Verify borated water volume in each SIT is [28% narrow range each SIT is 29% and 69% (1802 cubic feet) and 72% (% narrow range). narrow range (1914 cubic feet)]. SR 3.5.1.3 SR 3.5.1.3 Verify nitrogen cover pressure in Verify nitrogen cover-pressure in 2 each SIT is [615] psig and [655] each SIT is 40.6 kg/cm G 2 psig. (578 psig) and 43.9 kg/cm G (624 psig). SR 3.5.1.4 SR 3.5.1.4 Verify boron concentration in each Verify boron concentration in each SIT is [1500] ppm and [2800] SIT is 2,300 ppm and ppm. 4,400 ppm. SR 3.5.1.3 SR 3.5.1.5 Verify power is removed from each Verify power is removed from each SIT isolation valve operator when SIT isolation valve operator when pressurizer pressure is pressurizer pressure is 2 [2000] psia. 50.3 kg/cm A (715 psia). None SR 3.5.1.6 Periodic verification that the Added by RAI Verify isotopic concentration of isotopic concentration of 496-8630, Question B-10 in each SIT is within the limit Boron-10 in each SIT is within 6.03-10, Revision 2. specified in the COLR. the limit specified in the COLR ensures that the Boron-10 FREQUENCY isotopic concentration assumed 24 months KEPCO & KHNP 119

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) in the safety analysis is available. Since Boron-10 in the SITs is not directly exposed to a significant neutron flux and the IRWST water used as inventory for the SITs is only mixed with the reactor coolant during refueling outages, the Frequency of 24 months is considered conservative. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk. 3.5.2 ECCS - Operating LCO 3.5.2 LCO 3.5.2 See Section III.3.1 Two ECCS trains Shall be Four trains of SIS shall be OPERABLE. OPERABLE. APPLICABILITY APPLICABILITY See Section III.3.2.2 MODES 1, 2, MODES 1, 2, and 3. MODE 3 with pressurizer pressure [1700] psia. CONDITION CONDITION

                         -----REVIEWERS NOTE-----

The adoption of this Condition is contingent upon implementation of a program to perform a contemporaneous assessment of the overall impact on safety of proposed plant configurations prior to performing and during performance of maintenance activities that remove equipment from service. A. One LPSI subsystem A. One train inoperable. Inoperable. KEPCO & KHNP 120

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) B. One or more trains inoperable B. Two trains inoperable and for reasons other than diagonally oriented with respect Condition A. to the reactor vessel (Trains 1 and 3, or Trains 2 and 4). C. Required Action and associated C. Required Action and associated Completion Time not met. Completion Time of Condition A or B not met. D. Less than 100% of the ECCS D. Two or more trains inoperable flow equivalent to a single for reasons other than OPERABLE train available. Condition B. REQUIRED ACTION REQUIRED ACTION See III.3.2.2 A.1 Restore subsystem to A.1 Restore train to OPERABLE OPERABLE status. status. B.1 Restore train(s) to OPERABLE B.1. Verify two trains diagonally status. oriented with respect to the reactor vessel are OPERABLE. AND B.2. Restore trains to OPERABLE status. C.2 Reduce pressurizer pressure C.2 Be in MODE 4. See III.3.2.2 to < [1700] psia. SURVEILLANCE SURVEILLANCE The valves with power to the SR 3.5.2.1 SR 3.5.2.1 valve operator removed are not Verify the following valves are in Verify the following hot leg injection applicable for APR1400. the listed position with power to the isolation valves are locked in the valve operator removed [and key close position: SI-321, SI-331, locked in position]. SI-604, and SI-609. SR 3.5.2.2 SR 3.5.2.2 Activities for gas accumulation

                                                               -------------------NOTE------------------ management are considered.

Not required to be met for system KEPCO & KHNP 121

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) vent flow paths opened under administrative control. Verify each ECCS manual, Verify each SIS manual, power operated, and automatic power-operated, and automatic valve in the flow path, that is not valve in the flow path that is not locked, sealed, or otherwise locked, sealed, or otherwise secured in position, is in the correct secured in position is in correct position. position. SR 3.5.2.3 SR 3.5.2.3 TSTF-523 (Managing Gas Verify ECCS piping is full of water. Verify SIS piping locations Accumulation) is applied to susceptible to gas accumulation APR1400 Technical are sufficiently filled with water. Specification SR 3.5.2.4 SR 3.5.2.4 Verify each ECCS pump's Verify each SIS pump develops developed head at the test flow required differential pressure on 2 point is greater than or equal to the minimum flow of 123.8 kg/cm D required developed head. (1,761 psid). SR 3.5.2.5 SR 3.5.2.5 The SI pumps are tested at rated [ Verify each charging pump Verify each SIS pump develops a flow condition (in addition to the develops a flow of [36] gpm at a flow of 3,407 L/min (900 gpm) at miniflow condition) during power discharge pressure of [2200] a differential pressure operations to enhance the 2 psig. 86.9 kg/cm D (1,236 psid). capability of monitoring pump performance degradation. SR 3.5.2.6 SR 3.5.2.6 Not locked, sealed, or otherwise Verify each ECCS automatic valve Verify each SIS train automatic secured in position is in the flow path, that is not locked, valve in the flow path actuates to unnecessary in SR 3.5.2.6. sealed, or otherwise secured in correct position on an actual or position, actuates to the correct simulated actuation signal. position on an actual or simulated actuation signal. SR 3.5.2.8 None There is no LPSI pump in Verify each LPSI pump stops on an APR1400 plant design. actual or simulated actuation signal. KEPCO & KHNP 122

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.5.2.9 None The automatic valve and the part [ Verify, for each ECCS throttle of the power operated valves valve listed below, each position which have throttling function are stop is in the correct position. included in SR 3.5.2.2. SR 3.5.2.10 SR 3.5.2.8 Verify, by visual inspection, each Verify, by inspection, that the ECCS train containment sump IRWST, holdup volume tank suction inlet is not restricted by (HVT), IRWST strainers, HVT trash debris and the suction inlet trash racks and IRWST spillway are not racks and screens show no restricted by debris and strainers evidence of structural distress or and trash racks show no evidence abnormal corrosion. of structural distress or abnormal corrosion. 3.5.3 ECCS - Shutdown LCO 3.5.3 LCO 3.5.3 See III.3.1 One high pressure safety injection Two trains of SIS diagonally (HPSI) train shall be OPERABLE. oriented with respect to the reactor vessel shall be OPERABLE. APPLICABILITY APPLICABILITY See III.3.2.2 MODE 3 with pressurizer pressure MODES 4 and 5,

                                       < [1700] psia,               MODE 6 with RCS level < 39.7 m MODE 4.                                             (130 ft 0 in).

ACTIONS ACTIONS See III.3.2.2

                         -----------------NOTE-----------------     None LCO 3.0.4.b is not applicable to ECCS High Pressure Safety Injection subsystem when entering MODE 4.

A. Required HPSI train A. Required SIS trains inoperable. inoperable. B. Required Action and B. Required Action and associated Completion Time associated Completion Time of not met. Condition A not met. KEPCO & KHNP 123

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION See III.3.2.2 A.1 Restore required HPSI train to A.1 Restore required SIS trains to OPERABLE status. OPERABLE status. B.1 Be in MODE 5 B.1 Initiate actions to restore RCS level 39.7 m (130 ft 0 in). AND B.2 Reduce RCS cold leg temperature to < 57.2°C (135°F). SURVEILLANCE SURVEILLANCE SR 3.5.3.1 SR 3.5.3.1 The following SRs are applicable: The following SRs are applicable: [SR 3.5.2.1] SR 3.5.2.1, SR 3.5.2.2 SR 3.5.2.2, [SR 3.5.2.3] SR 3.5.2.3, SR 3.5.2.4 SR 3.5.2.4, SR 3.5.2.5, SR 3.5.2.6 SR 3.5.2.6, SR 3.5.2.7 SR 3.5.2.7, and SR 3.5.2.8. [SR 3.5.2.9] SR 3.5.2.10 3.5.4 Refueling Water LCO 3.5.4 LCO 3.5.4 See II.5 Tank (RWT) The RWT shall be OPERABLE. The IRWST shall be OPERABLE. APPLICABILITY APPLICABILITY MODES 1, 2, 3, and 4. MODES 1, 2, 3, 4 and 5, See III.3.2.3 MODE 6 with RCS level < 39.7 m (130 ft 0 in). KEPCO & KHNP 124

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CONDITION CONDITION Related A. RWT boron concentration not A. IRWST boron concentration not See III.3.2.3 REQUIRED within limits. within limits. ACTIONs and COMPLETIONs are OR changed. C. RWT borated water temperature IRWST B-10 isotopic not within limits. concentration not within limits. OR IRWST water temperature not within limits. B. Required Action and associated C. Required Action and associated See III.3.2.3 Completion Time of Condition A Completion Time of Condition A not met. or B not met in MODE 1, 2, 3, or 4. E. Required Action and associated Completion Time of Condition C or D not met. D. RWT inoperable for reasons B. IRWST water volume not within See III.3.2.3 other than Condition A or C. limits. None D. Required Action and See III.3.2.3 associated Completion Time of Condition A or B not met in MODE 5 or MODE 6 with RCS level < 39.7 m (130 ft 0 in). REQUIRED ACTION REQUIRED ACTION B.1

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

LCO 3.0.4.a is not applicable when None See III.3.2.3 entering MODE 3 or MODE 4. Be in MODE 3. E.1 Be in MODE 3. C.1 Be in MODE 3. KEPCO & KHNP 125

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) AND AND E.2 Be in MODE 5. C.2 Be in MODE 5. None D.1 Initiate action to restore RCS See III.3.2.3 level to 39.7 m (130 ft 0 in). AND D.2 Reduce RCS cold leg temperature to < 57.2°C (135°F). SURVEILLANCE SURVEILLANCE SR 3.5.4.1 SR 3.5.4.1 The NOTE is not necessary for

                         -------------NOTE-------------                                            APR1400 since the IRWST is

[ Only required to be performed None located in the reactor when ambient air temperature is containment building and is not [40]°F or [100]°F. ] affected by changing the

                         ----------------------------------                                        ambient air temperature.

Verify RWT borated water Verify IRWST water temperature is temperature is [40]°F and 10°C (50°F) and 49°C (120°F). [100]°F. SR 3.5.4.2 SR 3.5.4.2 Verify RWT borated water volume Verify IRWST water volume is 3 is [362,800 gallons, (88)%] 2,373.5 m (627,000 gal) and 3 [above the ECCS suction 2,540.6 m (671,162 gal) (i.e., connection]. 74.43% and 79.67%). SR 3.5.4.3 SR 3.5.4.3 Verify RWT boron concentration is Verify IRWST boron concentration [1720] ppm and [2500] ppm. is 4,000 ppm and 4,400 ppm. None SR 3.5.4.4 Verify isotopic concentration of B-10 in the IRWST is within the limit specified in the COLR. KEPCO & KHNP 126

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) FREQUENCY 24 months 3.5.5 Trisodium LCO 3.5.4 LCO 3.5.4 This is an intrinsic design Phosphate (TSP) The TSP baskets shall contain The TSP baskets shall contain characteristic of APR1400. 3 3 3 [291] ft of active TSP. 29.5 m (1,042 ft ) of active TSP. The required volume of TSP for APR1400 is presented in Table SURVEILLANCE SURVEILLANCE 6.5-4 of Tier 2. SR 3.5.5.1 SR 3.5.5.1 Verify the TSP baskets contain Verify the TSP baskets contain 3 3 3 [291] ft of trisodium phosphate. 29.5 m (1,042 ft ) of TSP. See II.5 3.6 CONTAINMENT SYSTEMS 3.6.1 Containment - Same as NUREG-1432 3.6.2 Containment Air REQUIRED ACTION REQUIRED ACTION See II.3.3 Locks D.2 --------------NOTE-------------- D.2 Be in MODE 5. LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. COMPLETION TIME COMPLETION TIME See II.3.3 D.2 12 hours D.2 36 hours 3.6.3 Containment ACTIONS ACTIONS The NOTE reflects APR1400 Isolation Valves ---------------NOTES--------------- ---------------NOTES--------------- plant specific design.

1. Penetration flow paths [except 1. Penetration flow paths (except - NUREG-1432 : 42 inch for [24] inch purge valve for 1219.2 mm (48 in) purge valve - APR1400 : 48 inch penetration flow paths] may be penetration flow paths) may be unisolated intermittently under unisolated intermittently under administrative controls. administrative controls.

CONDITION CONDITION A. ---------------NOTE--------------- A. ---------------NOTE--------------- Condition A of NUREG-1432 Related Only applicable to the Only applicable to penetration only applicable to the REQUIRED [containment sump supply flow paths with two or more containment isolation valves that ACTION and valves to the ECCS and containment isolation valves. do not meet the conditions to COMPLETION KEPCO & KHNP 127

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) containment spray pumps]. -------------------------------------- extend the Completion Time to 7 TIME are changed.

                           ---------------------------------------       One or more penetration flow         days. APR1400 does not adopt One or more penetration flow                  paths with one containment           NUREG-1432.

paths with one containment isolation valve inoperable isolation valve inoperable. (except for purge valve leakage not within limit). B. ---------------NOTE--------------- B. ---------------NOTE--------------- Only applicable to penetration Only applicable to those flow paths with two [or more] penetration flow paths with two containment isolation valves. or more containment isolation

                           ---------------------------------------      valves.

One or more penetration flow --------------------------------------- paths with one containment One or more penetration flow isolation valve inoperable [for paths with two containment reasons other than Condition[s] isolation valves inoperable A, E, [and F]]. (except for purge valve leakage not within limit). REQUIRED ACTION REQUIRED ACTION See II.3.3 AND None B.2 ------NOTES-------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated. COMPLETION TIME COMPLETION TIME See II.3.3 KEPCO & KHNP 128

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) B.1 [7 days] B.1 1 hour B.2 Once per 31 days for None isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment] C. ---------------NOTE--------------- C. ---------------NOTE--------------- APR1400 does not adopt Only applicable to penetration Only applicable to those NUREG-1432. flow paths with two [or more] penetration flow paths with only containment isolation valves. one containment isolation valve However APR1400 Condition-C

                           ----------------------------------------     and a closed system.                  is similar to NUREG-1432,
                                                                      --------------------------------------- Condition D except the One or more penetration flow              One or more penetration flow           bracketed options and paths with two [or more]                  paths with one containment             Completion Time is more containment isolation valves              isolation valve inoperable.            conservative.

inoperable [for reasons other than Condition[s] E [and F]]. REQUIRED ACTION REQUIRED ACTION None AND C.2 -------------NOTE------------ Isolation devices in high radiation areas may be verified by use of administrative means. Verify affected penetration flow path is isolated. KEPCO & KHNP 129

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) COMPLETION TIME COMPLETION TIME See II.3.3 C.1 1 hour C.1 4 hours None C.2 Once per 31 days D. ---------------NOTE--------------- D. None Only applicable to penetration flow paths with only one containment isolation valve and a closed system. One or more penetration flow One or more penetration flow paths with one containment paths with one or more isolation valve inoperable. containment purge valves not within purge valve leakage limits. REQUIRED ACTION REQUIRED ACTION D.1 Isolate the affected D.1 Isolate affected penetration flow path by use of penetration flow path by at least one closed and use of at least one closed de-activated automatic valve, and deactivated closed manual valve, or blind automatic valve with flange. resilient seals, closed manual valve with resilient seals, or blind flange. None AND D.3 Perform SR 3.6.3.6 for resilient seal purge valves closed to comply with Required Action D.1. COMPLETION TIME COMPLETION TIME See II.3.3 D.1 72 hours for those D.1 24 hours KEPCO & KHNP 130

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) penetrations that do not met the 7 day criteria AND 7 days for those penetrations that meet the 7 day criteria D.2 Once per 31 days D.2 Once per 31 days for isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment None D.3 Once per 92 days E. [ One or more secondary None containment bypass leakage [or purge valve leakage] not within limit. F. [ One or more penetration flow None paths with one or more containment purge valves not within purge valve leakage limits. G. Required Action and associated E. Required Action and associated Completion Time not met. Completion Time not met. REQUIRED ACTION REQUIRED ACTION G.1 Be in MODE 3. E. 1 Be in MODE 3. KEPCO & KHNP 131

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) AND E.2 Be in MODE 5. G.2 -------------NOTE------------ LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. COMPLETION TIME COMPLETION TIME G.2 12 hours E.2 36 hours SURVEILLANCE SURVEILLANCE The SR reflects APR1400 plant SR 3.6.3.1 [Verify each [42] inch SR 3.6.3.1 Verify each 1219.2 mm specific design. purge valve is sealed closed (48 inch) purge valve is sealed - NUREG-1432 : 42 inch except for one purge valve in a closed except for one purge - APR1400 : 48 inch penetration flow path while in valve in a penetration flow path Condition E of this LCO. while in Condition D of this LCO. SR 3.6.3.8 [ Verify each [ ] inch None Design concept for containment containment purge valve is purge valve is different between blocked to restrict the valve NUREG-1432 and APR1400. from opening > [50]%. SR 3.6.3.9 [ Verify the combined None The SR is not applicable leakage rate for all secondary because it deals with dual containment bypass leakage containments. paths is [La] when pressurized to [ psig]. 3.6.4 Containment LCO 3.6.4 LCO 3.6.4 Pressure Containment pressure shall be Containment pressure shall be 2

                          -0.3 psig and  +1.5 psig.           -0.007 kg/cm G (-0.1 psig) and 2
                                                                +0.07 kg/cm G (+1.0 psig).

REQUIRED ACTION REQUIRED ACTION For application of MODE 4, the B.2 ------------NOTE-------------- B.2 None guidance, as specified in LCO 3.0.4.a is not applicable Section 11 of NUMARC 93-01 when entering MODE 4. and WCAP-16364-NP, shall be

                               ----------------------------                                          followed.

KEPCO & KHNP 132

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Be in MODE 4. Be in MODE 5. (Same reason described in LCO 3.6.2) COMPLETION TIME COMPLETION TIME Same reason described in LCO B.2 12 hours B.2 36 hours 3.6.2 (See LCO 3.6.2) 3.6.5 Containment Air REQUIRED ACTION REQUIRED ACTION See II.3.3 Temperature B.2 ------------NOTE-------------- B.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. COMPLETION TIME COMPLETION TIME B.2 12 hours B.2 36 hours 3.6.6 Containment LCO 3.6.6 LCO 3.6.6 Containment Cooling function is Item name is Spray and Cooling Two containment spray trains and Two Containment Spray divisions included in the Containment changed. System two containment cooling trains shall be OPERABLE. Spray System. - Containment shall be OPERABLE. "Train" is changed to "Division". Spray and Cooling System Containment Spray System Containment Spray System provides the heat removal function from containment atmosphere following a LOCA. Containment Cooling System does not apply for APR1400. COMPLETION TIME COMPLETION TIME See III.6.2.1 A.1 [7] days A.1 72 hours KEPCO & KHNP 133

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION REQUIRED ACTION See II.3.3 B.2 --------------NOTE-------------- B.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. CONDITION CONDITION Containment Cooling function is C. One containment cooling train None included in the Containment inoperable. Spray System. D. One containment spray and one None containment cooling train inoperable. E. Two containment cooling trains None inoperable. F. Required Action and associated None Completion Time of Condition C, D, or E not met. G. Two containment spray trains C. Two containment spray "Train" is changed to "Division". inoperable. divisions inoperable. OR Any combination of three or more trains inoperable. SURVEILLANCE SURVEILLANCE Containment Cooling function is NOTE was added SR 3.6.6.1 SR 3.6.6.1 included in the Containment to SR 3.6.6.1 by None ------------------ NOTE ----------------- Spray System. RAI 478-8568, Not required to be met for system Question 16-140, vent flow paths opened under Revision 1. administrative control.

                                                                    ---------------------------------------------                                   Activities for gas accumulation SR 3.6.6.2 Operate each                    None                                                                            management are containment cooling train fan                                                                                         considered.

KEPCO & KHNP 134

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) unit for 15 minutes. SR 3.6.6.7 added by RAI 478-8568, SR 3.6.6.3 Verify each containment None Question 16-140, cooling train cooling water flow Revision 1. rate is [2000] gpm to each fan cooler. SR 3.6.6.4 [ Verify the containment SR 3.6.6.6 Verify the containment spray piping is full of water to spray piping is full of water to the [100] ft level in the the 26.213 m (86 ft) level in the containment spray header. containment spray header. SR 3.6.6.8 Verify each containment None cooling train starts automatically on an actual or simulated actuation signal. None SR 3.6.6.7 Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water. 3.6.7 Spray Additive LCO 3.6.7 None See III.6.2.2 System The Spray Additive System shall be OPERABLE. Addition None 3.6.7 Containment Penetrations - During reduced RCS inventory Related ACTIONS

 - Containment                                                      Shutdown Operations             operation, a release of fission   and Penetrations -                                                                                   products within the containment   SURVEILLANCE Shutdown Operations                                        LCO The containment building          to the environment is restricted. REQUIREMENTS penetrations shall be in the                                      are added.

following status:

a. The equipment hatch closed and held in place by a minimum of [four bolts,]
b. One door in each airlock KEPCO & KHNP 135

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) closed,

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:
1. Closed by a manual or automatic isolation valve, or blind flange, or
2. Exhausting through OPERABLE Containment Purge System air cleaning units (ACUs), and is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

APPLICABILITY MODE 5 with any Reactor Coolant System (RCS) loop not filled, MODE 6 with the water level

                                                         < 7.0 m (23 ft) above the top of the reactor vessel flange.
                                                         -------------NOTE------------

The equipment hatch shall be closed and held in place by a minimum of [four bolts] before opening the pressurizer manway in MODE 5. KEPCO & KHNP 136

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.6.8 Shield Building - None APR1400 does not have this Exhaust Air system. Cleanup System (SBEACS) 3.6.9 Hydrogen Mixing - None See III.6.2.3 System (HMS) 3.6.10 Iodine Cleanup - None See III.6.2.4 System (ICS) 3.6.11 Shield Building - None APR1400 does not have this system. 3.6.12 Vacuum Relief - None APR1400 does not have this Valves system. 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety CONDITION CONDITION Valves (MSSVs) B Required Action and associated B Required Action and associated Completion Time not met. Completion Time not met. OR OR One or more steam generators One or more steam generators with less than [two] MSSVs with less than five MSSVs OPERABLE. OPERABLE. REQUIRED ACTION REQUIRED ACTION A.2 Reduce the [variable A.2 Reduce maximum variable overpower trip - high] setpoint overpower trip setpoint in [ceiling] in accordance with accordance with Table 3.7.1-1. Table 3.7.1-1. SURVEILLANCE SURVEILLANCE There is no difference of bases SR 3.7.1.1 SR 3.7.1.1 for surveillance requirements Verify each required MSSV lift Verify each required MSSV is between NUREG-1432 and setpoint per Table 3.7.1-2 in within +/-3% of the lift setting value APR1400. accordance with the Inservice stated in Table 3.7.1-2, in Testing Program. Following accordance with the In-service testing, lift settings shall be within Testing Program. If the lift setting is

                         +/- 1%.                                  found to be outside the calibration KEPCO & KHNP                                                                                                                                           137

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) tolerance of +/-1% of the lift setting value stated in Table 3.7.1-2, the valve lift setting shall be reset to within the calibration tolerance. Table 3.7.1-2 Table 3.7.1-2 LIFT SETTING (psig +/- [3]%) LIFT SETTING (psig +/-1%) None -------------NOTE------------ Each MSSVs as-found lift setting shall be within +/-3% of the lift setting value stated in Table 3.7.1-2 for the valve to be considered OPERABLE. The valves lift setting shall be reset to within the calibration tolerance of

                                                         +/-1% of the lift setting value stated in Table 3.7.1-2 if the lift setting is found to be outside the calibration tolerance.

3.7.2 Main Steam LCO 3.7.2 LCO 3.7.2 Isolation Valves [Two] MSIVs shall be OPERABLE. Four MSIVs shall be OPERABLE. (MSIVs) 3.7.3 Main Feedwater - Same as NUREG-1432 MFIV bypass valves Isolation Valves not included in (MFIVs) [and APR1400. [MFIV] Bypass Valves] 3.7.4 Atmospheric Dump REQUIRED ACTION REQUIRED ACTION A Note has been added in the Valves (ADVs) None A.1 ----------------NOTE----------------- ACTION to exclude the MODE LCO 3.0.4 is not applicable. change restriction of LCO 3.0.4.

                                                               ---------------------------------------- This exception allows entry into A.1 Restore MSADV line to             Restore MSADV line to                    the applicable MODE while OPERABLE status.                      OPERABLE status.                         relying on the ACTIONS with one MSADV line inoperable. This KEPCO & KHNP                                                                                                                                              138

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) exception is acceptable due to the redundant design of MSADV lines and the ability to restore the MSADV within 7 days while the plant remains at, or proceeds to, power operation. 3.7.5 Auxiliary LCO 3.7.5 LCO 3.7.5 Design concept and Feedwater (AFW) [Three] AFW trains shall be Two auxiliary feedwater (AFW) configuration for AFWS are System OPERABLE. divisions, each with one motor different between NUREG-1432 driven train and one turbine driven and APR1400. train, shall be OPERABLE.

                         -----------------NOTE-----------------      -----------------NOTE-----------------      - NUREG-1432 : 3 trains (Two Only one AFW train, which                   Only the motor driven train of one             motor driven pump trains and includes a motor driven pump, is            AFW division is required to be                 one turbine driven pump train) required to be OPERABLE in                  OPERABLE in MODE 4.

MODE 4. ------------------------------------------- - APR1400 : 4 trains (Two motor

                         -------------------------------------------                                               driven pump trains and two turbine driven pump trains)

ACTIONS ACTIONS Risk informed Technical

                         -----------------NOTE-----------------      None                                        Specification is not applied for LCO 3.0.4.b is not applicable.                                                          APR1400. (Refer to the
                         -------------------------------------------                                             justification of LCO 3.0.4.)

CONDITION CONDITION A. [ Turbine driven AFW train A. One AFW division with one train inoperable due to one inoperable in MODE 1, 2, or 3. inoperable steam supply. OR

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

Only applicable if MODE 2 has not been entered following refueling. One turbine driven AFW pump KEPCO & KHNP 139

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) inoperable in MODE 3 following refueling. REQUIRED ACTION REQUIRED ACTION A.1 Restore train to OPERABLE A.1 Restore affected equipment to status. OPERABLE status. COMPLETION TIME COMPLETION TIME [72] hours 7 days] B. One AFW train inoperable in B. Two AFW divisions with one MODE 1, 2, or 3 [for reasons train inoperable in MODE 1, 2, other than Condition A]. or 3. REQUIRED ACTION REQUIRED ACTION B.1 Restore AFW train to B.1 Restore two trains of an AFW OPERABLE status. division to OPERABLE status. C. Turbine driven AFW train C. One AFW division with two inoperable due to one trains inoperable in MODE 1, 2, inoperable steam supply. or 3. AND One motor driven AFW train inoperable. REQUIRED ACTION REQUIRED ACTION C.1 Restore the steam supply to C.1 Restore one train of affected the turbine driven train to AFW division to OPERABLE OPERABLE status. status. COMPLETION TIME COMPLETION TIME [24 or 48] hours [24] hours OR KEPCO & KHNP 140

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) C.2 Restore the motor driven AFW train to OPERABLE status. COMPLETION TIME [24 or 48] hours D. Required Action and associated D. Required Action and associated Completion Time of Condition A Completion Time of Condition [,B, or C] not met. A, B, or C not met. [ OR OR [Two] AFW trains inoperable in Three AFW trains inoperable in MODE 1, 2, or 3 for reasons MODE 1, 2, or 3. other than Condition C. ] REQUIRED ACTION REQUIRED ACTION D.1 Be in MODE 3. D.1 Be in MODE 3. AND AND D.2 Be in MODE 4. D.2 Be in MODE 4 without reliance upon SGs for heat removal. E. [[Three] AFW trains inoperable E. Four AFW trains inoperable in in MODE 1, 2, or 3. MODE 1, 2, or 3. REQUIRED ACTION REQUIRED ACTION E.1 Initiate action to restore one E.1 Initiate action to restore one AFW train to OPERABLE AFW train to OPERABLE status. status. F. Required AFW train inoperable F. Two AFW motor driven trains in MODE 4. inoperable in MODE 4. REQUIRED ACTION REQUIRED ACTION F.1 ------------NOTE------------ ------------NOTE------------ KEPCO & KHNP 141

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) LCO 3.0.3 and all other LCO LCO 3.0.3 and all other LCO Required Actions requiring Required Actions requiring MODE MODE changes are changes are suspended until one suspended until one AFW train AFW motor driven train is restored is restored to OPERABLE to OPERABLE status. status. ---------------------------------

                               ---------------------------------     F.1 Initiate action to restore one Initiate action to restore one            AFW motor driven train to AFW train to OPERABLE                     OPERABLE status.

status. SURVEILLANCE SURVEILLANCE SR 3.7.5.1 SR 3.7.5.1 Verify each AFW manual, power Verify each manual, operated, and automatic valve in power-operated, and automatic each water flow path and in both valve in the flow path of each AFW steam supply flow paths to the train and in the steam supply flow steam turbine driven pump, that is path of each AFW turbine driven not locked, sealed, or otherwise pump, that is not locked, sealed, or secured in position, is in the correct otherwise secured in position, is in position. the correct position. SR 3.7.5.2 SR 3.7.5.2

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

Not required to be performed for Not required to be performed for the turbine driven AFW pump until AFW turbine driven pumps until [24] hours after reaching [800] psig 24 hours after reaching 2 in the steam generators. 69.25 kg/cm G (985 psig) in steam

                         ------------------------------------------- generators.

Verify the developed head of each ------------------------------------------- AFW pump at the flow test point is Verify developed head of each greater than or equal to the AFW pump at flow test point is required developed head. greater than or equal to required developed head. SR 3.7.5.3 SR 3.7.5.3

                         -----------------NOTES-----------------     -----------------NOTE-----------------
1. Not required to be performed for Not required to be met in MODE 4 KEPCO & KHNP 142

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) the turbine driven AFW pump when steam generator is relied until [24] hours after reaching upon for heat removal. [800] psig in the steam ------------------------------------------- generators.

2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.

SR 3.7.5.4 SR 3.7.5.4

                         -----------------NOTES-----------------     -----------------NOTES-----------------
1. Not required to be performed for 1. Not required to be performed for the turbine driven AFW pump AFW turbine driven pumps until until [24] hours after reaching 24 hours after reaching 2

[800] psig in the steam 69.25 kg/cm G (985 psig) in generators. steam generators.

2. Not required to be met in 2. Not required to be met in MODE 4 when steam generator MODE 4 when steam generator is relied upon for heat removal. is relied upon for heat removal.

Verify each AFW pump starts Verify each AFW pump starts automatically on an actual or automatically on an actual or simulated actuation signal when in simulated actuation signal. MODE 1, 2, or 3. SR 3.7.5.5 SR 3.7.5.5 AFW is supplied from its Verify the proper alignment of the Verify proper alignment of required exclusive AFWST in APR1400 required AFW flow paths by flow paths of each train of each design. verifying flow from the condensate AFW division by verifying flow from storage tank to each steam the associated auxiliary feedwater generator. storage tank to the associated steam generator. 3.7.6 Condensate LCO 3.7.6 LCO 3.7.6 Design concept and Storage Tank The CST shall be OPERABLE. Two AFWSTs shall be configuration for AFWS are (CST) OPERABLE. different between NUREG-1432 and APR1400. KEPCO & KHNP 143

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

                                                                                                    - NUREG-1432: A common CST is used.
                                                                                                    - APR1400: Two 100% capacity Auxiliary Feedwater Storage Tanks (AFWSTs) are installed.

If one AFWST is not operable, the other AFWST as backup water source provides water to the steam generators. CONDITION CONDITION A. CST inoperable. A. One AFWST inoperable. REQUIRED ACTION REQUIRED ACTION A.1 Verify OPERABILITY of A.1 Verify OPERABILITY of backup water supply. backup water supply and the other AFWST. AND AND A.2 Restore CST to OPERABLE status. A.2 Restore AFWST to OPERABLE status. SURVEILLANCE SURVEILLANCE SR 3.7.6.1 SR 3.7.6.1 Verify CST level is [350,000] gal. Verify each AFWST level is 1,524,165 L (400,000 gal). 3.7.7 Component LCO 3.7.7 LCO 3.7.7 "Train" is changed to "Division". Cooling Two CCW trains shall be Two component cooling water Water (CCW) OPERABLE. (CCW) divisions shall be System OPERABLE. REQUIRED ACTION REQUIRED ACTION This is an intrinsic design A.1 -------------NOTE-------------- ----------------NOTES---------------- characteristic of APR1400. Enter applicable Conditions 1. Enter applicable Conditions and and Required Actions of Required Actions of LCO 3.8.1, "Train" is changed to "Division". LCO 3.4.6, "RCS Loops - AC Sources - Operating, for MODE 4," for shutdown emergency diesel generator cooling made inoperable by made inoperable by CCW. KEPCO & KHNP 144

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CCW. 2. Enter applicable Conditions and

                               -------------------------------------     Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," for shutdown cooling made inoperable by CCW.

Restore CCW train to A.1 Restore CCW division to OPERABLE status. OPERABLE status. B.2 -------------NOTES-------------- B.2 None LCO 3.0.4.a is not applicable See II.3.3 when entering MODE 4. Be in MODE 4. Be in MODE 5. 3.7.8 Service Water LCO 3.7.8 LCO 3.7.8 "Train" is changed to "Division". System (SWS) Two SFS trains shall be Two ESWS divisions shall be OPERABLE. OPERABLE. REQUIRED ACTION REQUIRED ACTION See II.3.3 B.2 -------------NOTE--------------- B.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. 3.7.9 Ultimate Heat Sink LCO 3.7.9 LCO 3.7.9 See III.7.2.1 (UHS) The UHS shall be OPERABLE. [Two] UHS [divisions] shall be OPERABLE. CONDITION CONDITION A. [One or more cooling towers A. [One UHS cooling tower See III.7.2.1 Related with one cooling tower fan inoperable.] REQUIRED inoperable. ACTIONs and COMPLETION TIMEs are changed. B. Required Action and associated B. [Required Action and associated See III.7.2.1 Completion Time of Condition A Completion Time of Condition A KEPCO & KHNP 145

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) or B not met. not met. OR] UHS inoperable [for reasons other than Condition A.]

                         ---------REVIEWERS NOTES--------              None                               CONDITION C of NUREG-1432 The [ ]°F is the maximum allowed                                                  is included in CONDITION B of UHS temperature value and is                                                      APR1400.

based on temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit. C. [Water temperature of the UHS

                             > [90]°F and  [ ]°F D. [Required Action and associated             None                               CONDITION D of NUREG-1432 Completion Time of Condition C                                                is included in CONDITION B of not met.                                                                      APR1400.

OR] UHS inoperable [for reasons other than condition A or C.] REQUIRED ACTION REQUIRED ACTION See II.3.3 B.2 -------------NOTES-------------- B.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4 Be in MODE 5 SURVEILLANCE SURVEILLANCE The SR reflects design SR 3.7.9.1 [ Verify water level of SR 3.7.9.1 Verify water level of characteristic of APR1400. UHS is [562] ft [mean sea UHS is [7.90 m (25.93 ft) level]. from the bottom of the basin]. KEPCO & KHNP 146

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.7.9.2 [Verify average water SR 3.7.9.2 Verify water temperature of UHS is temperature of UHS [basin] is [90]°F. [33.2°C (91.8°F)]. None SR 3.7.9.4 Other SRs are added because of [Verify each UHS manual, an intrinsic design characteristic power-operated, and automatic of APR1400. valve in the flow path servicing - SR 3.7.9.4 safety related equipment, that is - SR 3.7.9.5 not locked, sealed or otherwise - SR 3.7.9.6 secured in position, is in correct position.] None SR 3.7.9.5 [Verify each UHS automatic valve and each control valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to correct position on an actual or simulated actuation signal.] None SR 3.7.9.6 [Verify each cooling tower fan starts automatically on an actual or simulated actuation signal.] 3.7.10 Essential Chilled 3.7.10 3.7.10 "Train" is changed to "Division". Water (ECW) Essential Chilled Water (ECW) Essential Chilled Water System (ECWS) REQUIRED ACTION REQUIRED ACTION B.2 --------------NOTE-------------- B.2 None See II.3.3 LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. KEPCO & KHNP 147

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.7.11 Control Room 3.7.11 3.7.11 3.7.11 CREACS and 3.7.12 Emergency Air Control Room Emergency Air Control Room Heating, Ventilation, CREATCS of NUREG-1432 are Cleanup System Cleanup System (CREACS) and Air Conditioning (HVAC) combined into 3.7.11 Control (CREACS) System (CRHS) Room HVAC System (CRHS) of APR1400. LCO 3.7.11 LCO 3.7.11 LCO 3.7.11 and LCO 3.7.12 of Two CREACS trains shall be Two Control Room Emergency NUREG-1432 are combined into OPERABLE. Makeup Air Cleaning System LCO 3.7.11 of APR1400. (CREACS) divisions and two Control Room Supply and Return System (CRSRS) divisions of the CRHS shall be OPERABLE. APPLICABILITY APPLICABILITY During movement of [recently] During movement of irradiated fuel irradiated fuel assemblies. assemblies. CONDITION CONDITION A. One CREACS train inoperable A. One CREACS division for reasons other than inoperable for reasons other Condition B. than Condition C. None B. One CRSRS division inoperable. REQUIRED ACTION B.1 Restore CRSRS division to OPERABLE status. COMPLETION TIME 7 days B. One or more CREACS trains C. One or two CREACS divisions inoperable due to inoperable inoperable due to inoperable CRE boundary in MODE 1, 2, 3, CRE boundary in MODE 1, 2, 3, or 4. or 4. REQUIRED ACTION REQUIRED ACTION B.2 Verify mitigating actions C.2 Verify mitigating actions to KEPCO & KHNP 148

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) ensure CRE occupant ensure CRE occupant exposures to radiological, exposures to radiological, [toxic chemical, and smoke hazards gas,] and smoke hazards will will not exceed limits. not exceed limits. C. Required Action and associated D. Required Action and associated Completion Time of Condition A Completion Time of Condition or B not met in MODE 1, 2, 3, A, B, or C not met in MODE 1, or 4. 2, 3 or 4. REQUIRED ACTION REQUIRED ACTION See II.3.3 C.2 -------------NOTE------------- D.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. D. Required Action and associated E. Required Action and associated Completion Time of Condition A Completion Time of Condition A not met [in MODE 5 or 6, or] or B not met [in MODE 5 or 6, during movement of [recently] or] during movement of irradiated fuel assemblies. irradiated fuel assemblies. REQUIRED ACTION REQUIRED ACTION D.1 ---------------NOTE-------------- [----------------NOTE------------------- The NOTE for toxic gas isolation Place in toxic gas protection Place CRHS in toxic gas mode is enclosed in brackets as mode if automatic transfer to isolation mode if automatic a COL action item in APR1400. toxic gas protection mode is transfer to toxic gas isolation inoperable. mode is inoperable.

                            ------------------------------------- ---------------------------------------------]

Place OPERABLE CREACS E.1 Place CREACS and CRSRS of train in emergency radiation an OPERABLE CRHS division protection mode. in emergency mode. OR OR D.2 Suspend movement of E.2[.1] Suspend movement of [recently] irradiated fuel irradiated fuel assemblies. assemblies. KEPCO & KHNP 149

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) [AND E.2.2 Suspend operations with a The bracketed Required potential for releasing ACTION E.2.2 is added as a radioactivity from the Gaseous COL action item in APR1400. Radwaste System. E. Two CREACS trains inoperable F. Two CREACS divisions [in MODE 5 or 6, or] during inoperable [in MODE 5 or 6, or] movement of [recently] during movement of irradiated irradiated fuel assemblies. fuel assemblies. OR OR One or more CREACS trains One or two CREACS divisions inoperable due to an inoperable inoperable due to inoperable CRE boundary [in MODE 5 or 6, CRE boundary [in MODE 5 or 6, or] during movement of or] during movement of [recently] irradiated fuel irradiated fuel assemblies. assemblies. REQUIRED ACTION REQUIRED ACTION E.1 Suspend movement of F.1 Suspend movement of [recently] irradiated fuel irradiated fuel assemblies. assemblies. [AND F.2 Suspend operations with a The bracketed Required potential for releasing ACTION F.2 is added as a COL radioactivity from the Gaseous action item in APR1400. Radwaste System. KEPCO & KHNP 150

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) F. Two CREACS trains inoperable G. Two CREACS divisions in MODE 1, 2, 3, or 4 for inoperable in MODE 1, 2, 3, or 4 reasons other than Condition B. for reasons other than Condition C. OR Two CRSRS divisions inoperable in MODE 1, 2, 3, or 4. SURVEILLANCE SURVEILLANCE TSTF-522-A, Rev. 0 (Revise SR 3.7.11.1 SR 3.7.11.1 Ventilation System Surveillance Operate each CREACS train for Operate each CREACS division for Requirements to Operate for [ 10 continuous hours with 15 minutes with heaters 10 hours per Month) is applied to heaters operating or (for systems operating. APR1400 NRC DCD Technical without heaters) 15 minutes]. Specifications. SR 3.7.11.3 SR 3.7.11.3 Verify each CREACS train actuates Verify active components in each on an actual or simulated actuation CRHS division actuate on an signal. actual or simulated actuation signal. None SR 3.7.11.5 SR 3.7.11.5 from combining Verify each CRSRS division has 3.7.11 (CREACS) and 3.7.12 the capacity to remove design heat (CREATCS) of NUREG-1432 load. into 3.7.11 (CRHS) of APR1400 and reflects SR 3.7.12.1 of NUREG-1432. 3.7.12 3.7.12 3.7.11 3.7.11 CREACS and 3.7.12 Control Room Control Room Emergency Air Control Room Heating, Ventilation, CREATCS of NUREG-1432 are Emergency Air Temperature Control System and Air Conditioning (HVAC) combined into 3.7.11 Control Temperature Control (CREATCS) System (CRHS) Room HVAC System (CRHS) of System (CREATCS) APR1400. LCO 3.7.12 LCO 3.7.11 LCO 3.7.11 and LCO 3.7.12 of Two CREATCS trains shall be Two Control Room Emergency NUREG-1432 are combined into OPERABLE. Makeup Air Cleaning System LCO 3.7.11 of APR1400. KEPCO & KHNP 151

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) (CREACS) divisions and two Control Room Supply and Return System (CRSRS) divisions of the CRHS shall be OPERABLE. 3.7.13 3.7.13 3.7.12 3.7.12 ABCAEES of APR1400 Emergency Core Cooling Emergency Core Cooling System Auxiliary Building Controlled Area has both functions of 3.7.13 System (ECCS) Pump (ECCS) Pump Room Exhaust Air Emergency Exhaust System ECCS PREACS and 3.7.15 Room Exhaust Air Cleanup System (PREACS) (ABCAEES) PREACS of NUREG-1432. Cleanup System LCO 3.7.13 LCO 3.7.12 3.7.12 ABCAEES of APR1400 (PREACS) Two ECCS PREACS trains shall Two ABCAEES divisions shall be serves all areas which are be OPERABLE. OPERABLE. served by 3.7.13 ECCS

                         --------------NOTE------------      --------------NOTE------------       PREACS and 3.7.15 PREACS of The ECCS pump room                  The mechanical penetration     NUREG-1432.

boundary may be opened room and safety-related intermittently under mechanical equipment room The ECCS pump rooms of administrative control. boundary may be opened NUREG-1432 are included in the

                         -----------------------------------       intermittently under           safety-related mechanical administrative control.        equipment rooms of APR1400.

CONDITION CONDITION A. One ECCS PREACS train A. One ABCAEES division inoperable. inoperable. B. Two ECCS PREACS trains B. Two ABCAEES divisions inoperable due to inoperable inoperable due to inoperable ECCS pump room boundary. mechanical penetration room or safety-related mechanical equipment room boundary. REQUIRED ACTION REQUIRED ACTION A.1 Restore ECCS PREACS train A.1 Restore inoperable ABCAEES to OPERABLE status. division to OPERABLE status. B.1 Restore ECCS pump room B.1 Restore mechanical boundary to OPERABLE status. penetration room and safety-related mechanical equipment room boundary to KEPCO & KHNP 152

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) operable status. C.2.---------NOTE------------------- See II.3.3 LCO 3.0.4.a is not applicable C.2. None when entering MODE 4. Be in MODE 4. Be in MODE 5. SURVEILLANCE SURVEILLANCE TSTF-522-A, Rev. 0 (Revise SR 3.7.13.1 SR 3.7.12.1 Ventilation System Surveillance Operate each ECCS PREACS train Operate each ABCAEES division Requirements to Operate for for [ 10 continuous hours with for 15 minutes with heaters 10 hours per Month) is applied to heaters operating or (for systems operating. APR1400 NRC DCD Technical without heaters) 15 minutes]. Specifications. SR 3.7.13.4 SR 3.7.12.4 Verify one ECCS PREACS train Verify the mechanical penetration can maintain a negative pressure rooms and the safety-related [ ] inches water gauge relative to mechanical equipment rooms can atmospheric pressure during the be maintained at a pressure of [post accident] mode of operation -6.35 mm (-0.25 inches) water at a flow rate of [20,000] cfm. gauge with respect to the adjacent areas using one ABCAEES division during post-accident mode of operation at a flow rate of 5,097 cmh (3,000 cfm) within 300 seconds after a start signal. SR 3.7.13.5 [Verify each None The filter bypass damper is not ECCS PREACS filter bypass used in ABCAEES of APR1400. damper can be opened. 3.7.14 LCO 3.7.14 Two FBACS trains LCO 3.7.13 Two FHAEES divisions "Train" is changed to "Division". Fuel Building Air shall be OPERABLE. shall be OPERABLE Cleanup System (FBACS) APPLICABILITY APPLICABILITY [MODES 1, 2, 3, and 4,] During movement of irradiated fuel During movement of [recently] assemblies in the fuel handling irradiated fuel assemblies. area. KEPCO & KHNP 153

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) CONDITION CONDITION A. One FBACS train inoperable. A. One FHAEES division inoperable. B. Two FBACS trains inoperable None Related due to inoperable fuel building REQUIRED boundary in MODE 1, 2, 3, or 4. ACTIONs and COMPLETION C. [ Required Action and None TIMEs are deleted. associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4. OR Two FBACS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B. D. Required Action and Associated B. Required Action and associated Completion Time [of Condition Completion Time of Condition A A] not met during movement of not met during movement of [recently] irradiated fuel irradiated fuel assemblies in fuel assemblies in the fuel building. handling area. E. Two FBACS trains inoperable C. Two FHAEES divisions during movement of [recently] inoperable during movement of irradiated fuel assemblies in the irradiated fuel assemblies in fuel fuel building. handling area. SURVEILLANCE SURVEILLANCE TSTF-522-A, Rev. 0 (Revise SR 3.7.14.1 SR 3.7.13.1 Ventilation System Surveillance Operate each FBACS train for Operate each FHAEES division for Requirements to Operate for [ 10 continuous hours with 15 minutes with heaters 10 hours per Month) is applied to heaters operating or (for systems operating. APR1400 NRC DCD Technical without heaters) 15 minutes]. Specifications. KEPCO & KHNP 154

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.7.14.4 SR 3.7.13.4 Verify one FBACS train can Verify one FHAEES division can maintain a negative pressure [ ] maintain a slightly negative inches water gauge with respect to pressure with respect to atmospheric pressure, during the atmospheric pressure during [post accident] mode of operation post-accident mode of operation at at a flow rate [3000] cfm. a flow rate of 8,495 cmh (5,000 cfm). SR 3.7.14.5 [Verify each None The filter bypass damper is not FBACS filter bypass damper can used in FHAEES of APR1400. be opened. 3.7.15 3.7.15 3.7.12 3.7.12 ABCAEES of APR1400 Penetration Room Penetration Room Exhaust Air Auxiliary Building Controlled Area has both function of 3.7.13 Exhaust Air Cleanup Cleanup System (PREACS) Emergency Exhaust System ECCS PREACS and 3.7.15 System (PREACS) (ABCAEES) PREACS of NUREG-1432. LCO 3.7.15 LCO 3.7.12 3.7.12 ABCAEES of APR1400

                         --------------NOTE------------            --------------NOTE------------       serves all areas those are served The penetration room                      The mechanical penetration     by 3.7.13 ECCS PREACS and boundary may be opened                    room and safety-related        3.7.15 PREACS of intermittently under                      mechanical equipment room      NUREG-1432.

administrative control. boundary may be opened

                         -----------------------------------             intermittently under administrative control.

REQUIRED ACTION REQUIRED ACTION C.2.---------NOTE------------------- B.2. None See II.3.3 LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. CONDITION CONDITION To adopt condition B, the B. Two PREACS trains inoperable None licensee should have guidance due to inoperable penetration room available describing boundary. compensatory measures to be KEPCO & KHNP 155

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) taken in the event of an intentional and unintentional entry into condition B. However, APR1400 does not have any guidance describing compensatory measures to be taken in the event of entry into condition B. For that reason, APR1400 does not adopt condition B. SURVEILLANCE SURVEILLANCE The filter bypass damper is not SR 3.7.15.4 [Verify each PREACS None used in ABCAEES of APR1400. filter bypass damper can be opened. 3.7.16 - Same as NUREG-1432 This item is Fuel Storage Pool Water equivalent to 3.7.14 Level Spent Fuel Pool Water Level (SFPWL) of APR1400. 3.7.17 LCO 3.7.17 LCO 3.7.15 This item is Fuel Storage Pool Boron The fuel storage pool boron The spent fuel pool (SFP) boron This is an intrinsic design equivalent to 3.7.15 Concentration concentration shall be [2000] concentration shall be 2,150 ppm characteristic of APR1400. Spent Fuel Pool ppm. and the SFP B-10 isotopic Boron concentration shall be 19.9% Concentration of (atomic percent). APR1400. ACTIONS ACTIONS

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

LCO 3.0.3 is not applicable. CONDITION CONDITION KEPCO & KHNP 156

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) A. Spent fuel pool boron A. Spent fuel pool boron concentration not within limit. concentration not within limits. OR Spent fuel pool B-10 isotopic concentration not within limits. REQUIRED ACTION REQUIRED ACTION

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

LCO 3.0.3 is not applicable.

                         ---------------------------------------------  A.1 Suspend movement of fuel A.1 Suspend movement of fuel                         assemblies in spent fuel assemblies in the fuel storage                pool.

pool. AND AND A.2.1 Initiate action to restore A.2.1 Initiate action to restore spent fuel pool boron fuel storage pool boron concentration and B-10 concentration to within limit. isotopic concentration to within limits. OR OR A.2.2 Initiate action to perform a fuel storage pool A.2.2 Initiate action to perform verification. a spent fuel pool verification. SURVEILLANCE SURVEILLANCE None SR 3.7.15.2 Verify isotopic concentration of B-10 in the SFP is 19.9% (atomic percent). 3.7.18 Spent Fuel Pool REQUIRED ACTION REQUIRED ACTION The action is defined for the This item is Storage A.1 -------------NOTE------------- A.1 -------------NOTE------------- storage location or moving equivalent to 3.7.16 LCO 3.0.3 is not applicable. LCO 3.0.3 is not applicable. destination of noncomplying fuel. Spent Fuel KEPCO & KHNP 157

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

                                ----------------------------------          ----------------------------------                                  Assembly Storage of APR1400.

Initiate action to move the Initiate action to move the noncomplying fuel assembly from noncomplying fuel from Region II to [Region 2]. Region I. 3.7.19 Secondary - Same as NUREG-1432 This item is Specific Activity equivalent to 3.7.17 Secondary Specific Activity of APR1400. 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources LCO 3.8.1 LCO 3.8.1 See III.4.2.1. Operating b. Two diesel generators (DGs) b. Division I and division II each capable of supplying one emergency diesel generators train of the onsite Class 1E AC (EDGs), each division capable of Electrical Power Distribution supplying one division of the System, and onsite Class 1E AC Electrical Power Distribution System and consisting of two EDGs (EDG A and EDG C for division I, and EDG B and EDG D for division II), and [c. Automatic load sequencers for c. Four automatic load sequencers Train A and Train B.] for EDG A, EDG B, EDG C, and EDG D. ACTIONS ACTIONS See III.4.2.1.

                          -----------------NOTE-----------------     None LCO 3.0.4.b is not applicable to DGs.

CONDITION CONDITION See III.4.2.1. B. One [required] DG inoperable. B. One or two EDGs in one division inoperable. KEPCO & KHNP 158

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) D. One [required] offsite circuit D. One offsite circuit inoperable. See III.4.2.1. inoperable. AND AND One or two EDGs in one One [required] DG inoperable. division inoperable. E. Two [required] DGs inoperable. E. One or two EDGs in each See III.4.2.1. division inoperable. F. ------------NOTE------------ F. None [ This Condition may be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event. One [required] [automatic load One automatic load sequencer sequencer] inoperable. inoperable. H. Three or more [required] AC H. Two offsite circuits and one or See III.4.2.1. sources inoperable. more EDGs inoperable. . OR One offsite circuit and one or two EDGs in each division inoperable REQUIRED ACTION REQUIRED ACTION G.2.---------NOTE----------- G.2. None See II.3.3 LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. KEPCO & KHNP 159

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE SR 3.8.1.2 SR 3.8.1.2 Verify each DG starts from standby Verify each EDG starts from conditions and achieves steady standby conditions and achieves state voltage [3740] V and steady state voltage 3,744 V and [4580] V, and frequency [58.8] 4,576 V, and frequency 58.8 Hz Hz and [61.2] Hz. and 61.2 Hz. SR 3.8.1.3 SR 3.8.1.3 Verify each DG is synchronized Verify each EDG is synchronized and loaded, and operates for 60 and loaded, and operates for 60 minutes at a load [4500] kW and minutes at a load 90% rating [5000] kW. and 100% rating. SR 3.8.1.4 SR 3.8.1.4 Verify each day tank [and engine Verify each day tank contains See III.4.2.3. mounted tank] contains [220] gal [2,404 L (635 gal)] of fuel oil. The capacity of day tank may of fuel oil. vary depending on manufacturers recommendations. However, the capacity of 635 gal is the value that has been validated to be an actual one through long-term applications in local nuclear plants. SR 3.8.1.5 SR 3.8.1.5 Check for and remove Check for and remove accumulated water from each day accumulated water and sediment tank [and engine mounted tank]. from each day tank and engine mounted tank. SR 3.8.1.7 SR 3.8.1.7

a. In [10] seconds, voltage a. In 17 seconds, voltage See III.4.2.3.

[3740] V and frequency [58.8] 3,744 V and frequency 58.8 Hz and Hz, and

b. Steady state voltage [3740] V, b. Steady state voltage 3,744 V, and [4580] V, and frequency and 4,576 V, and frequency

[58.8] Hz and [61.2] Hz. 58.8 Hz and 61.2 Hz. KEPCO & KHNP 160

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SR 3.8.1.9 SR 3.8.1.9

b. Within [3] seconds following load b. Within 3 seconds following load rejection, the voltage is rejection, the voltage is 3,744 V

[3740] V and [4580] V, and and 4,576 V, and SR 3.8.1.10 SR 3.8.1.10 Verify each DG does not trip, and Verify each EDG does not trip, and voltage is maintained [5000] V voltage is maintained 4,576 V during and following a load during and following a load rejection of [4500] kW and rejection of 90% rating and [5000] kW. 100% rating. SR 3.8.1.11 SR 3.8.1.11 See III.4.2.3.

                         -----------------NOTES-----------------    -----------------NOTES-----------------
2. This Surveillance shall not 2. This Surveillance shall not be normally be performed in performed in MODE 1, 2, 3, MODE 1, 2, 3, or 4. However, or 4. However, portions of the portions of the Surveillance may Surveillance may be performed be performed to reestablish to reestablish OPERABILITY OPERABILITY provided an provided an assessment assessment determines the determines the safety of the safety of the plant is maintained plant is maintained or or enhanced. Credit may be enhanced. Credit may be taken taken for unplanned events that for unplanned events that satisfy this SR. satisfy this SR.
c. 1. Energizes permanently c. 1. energizes connected loads in [10] permanently-connected loads in seconds, 19 seconds,
c. 3. Maintains steady state voltage c. 3. maintains steady state voltage

[3740] V and [4580] V, 3744 V and 4576 V, SR 3.8.1.12 SR 3.8.1.12 See III.4.2.3.

                         -----------------NOTES-----------------    -----------------NOTES-----------------
2. This Surveillance shall not 2. [This Surveillance shall not be normally be performed in performed in MODE 1 or 2.

MODE 1 or 2. However, However, portions of the portions of the Surveillance may Surveillance may be performed KEPCO & KHNP 161

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) be performed to reestablish to reestablish OPERABILITY OPERABILITY provided an provided an assessment assessment determines the determines the safety of the safety of the plant is maintained plant is maintained or or enhanced. Credit may be enhanced. Credit may be taken taken for unplanned events that for unplanned events that satisfy this SR. satisfy this SR.]

a. In [10] seconds after auto-start a. In 17 seconds after auto-start and during tests, achieves and during tests, achieves voltage [3740] V and frequency voltage 3,744 V and frequency

[58.8] Hz, 58.8 Hz,

b. Achieves steady state voltage b. Achieves steady state voltage

[3740] V and [4580] V and 3744 V and 4576 V and frequency [58.8] Hz and frequency 58.8 Hz and [61.2] Hz, 61.2 Hz, SR 3.8.1.13 SR 3.8.1.13

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

[ This Surveillance shall not [This Surveillance shall not be normally be performed in MODE 1 performed in MODE 1 or 2. or 2. However, this Surveillance However, this Surveillance may be may be performed to reestablish performed to reestablish OPERABILITY provided an OPERABILITY provided an assessment determines the safety assessment determines the safety of the plant is maintained or of the plant is maintained or enhanced. Credit may be taken for enhanced. Credit may be taken for unplanned events that satisfy this unplanned events that satisfy this SR. ] SR.] SR 3.8.1.14 SR 3.8.1.14

                         -----------------NOTES-----------------    -----------------NOTES-----------------
2. This Surveillance shall not 2. This Surveillance shall not be normally be performed in performed in MODE 1 or 2.

MODE 1 or 2. However, this However, this Surveillance may Surveillance may be performed be performed to reestablish to reestablish OPERABILITY OPERABILITY provided an KEPCO & KHNP 162

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) provided an assessment assessment determines the determines the safety of the safety of the plant is maintained plant is maintained or or enhanced. Credit may be enhanced. Credit may be taken taken for unplanned events that for unplanned events that satisfy this SR. satisfy this SR. ------------------------------------------

a. For [2] hours loaded [5250] a. For 2 hours loaded 105%

kW and [5500] kW and rating and 110% rating and;

b. For the remaining hours of the b. For the remaining hours of the test loaded [4500] kW and test loaded 90% rating and

[5000] kW. 100% rating. SR 3.8.1.15 SR 3.8.1.15 See III.4.2.3.

                         -----------------NOTES-----------------    -----------------NOTES-----------------
1. This Surveillance shall be 1. This Surveillance shall be performed within 5 minutes of performed within 5 minutes of shutting down the DG after the shutting down the EDG after the DG has operated [2] hours EDG has operated in 2 hours loaded [4500] kW and loaded 90% rating and

[5000] kW. 100% rating. Momentary transients outside of load range Momentary transients outside of do not invalidate this test. load range do not invalidate this ------------------------------------------ test.

a. In [10] seconds, voltage a. In 17 seconds, voltage

[3740] V and frequency 3,744 V and frequency [58.8] Hz and 58.8 Hz.

b. Steady state voltage [3740] V b. Steady state voltage 3,744 V and [4580] V, and frequency and 4,576 V, and frequency

[58.8] Hz and [61.2] Hz. 58.8 Hz and 61.2 Hz. SR 3.8.1.19 SR 3.8.1.19 See III.4.2.3.

c. 1. energizes permanently c. 1. energizes permanently connected loads in [10] connected loads in 19 seconds, seconds, KEPCO & KHNP 163

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3)

c. 3. achieves steady state voltage c. 3. achieves steady state voltage

[3740] V and [4580] V, 3,744 V and 4,576 V, SR 3.8.1.20 SR 3.8.1.20 See III.4.2.3.

a. In [10] seconds, voltage a. In 17 seconds, voltage 3,744

[3740] V and frequency V and frequency 58.8 Hz and [58.8] Hz and

b. Steady state voltage [3740] V b. Steady state voltage 3,744 V and [4580] V, and frequency and 4,576 V, and frequency

[58.8] Hz and [61.2] Hz. 58.8 Hz and 61.2 Hz. 3.8.2 AC Sources - LCO 3.8.2 LCO 3.8.2 See III.4.2.1. Shutdown b. One diesel generator (DG) b. One division of emergency capable of supplying one train of diesel generators (EDGs) the onsite Class 1E AC electrical capable of supplying one division power distribution subsystem(s) of the onsite Class 1E AC required by LCO 3.8.10. Electrical Power Distribution System required by LCO 3.8.10. APPLICABILITY APPLICABILITY [recently] irradiated During movement of [recently] During movement of irradiated fuel changed to irradiated fuel assemblies. assemblies. irradiated. CONDITION CONDITION See III.4.2.1. B. One required DG inoperable. B. One or two required EDGs in one division inoperable. 3.8.3 Diesel Fuel Oil, CONDITION CONDITION See III.4.2.3. Lube Oil, and E. One or more DGs with starting E. One or more EDGs with starting Starting Air air receiver pressure < [225] air receiver pressure The air pressure of starting air psig and [125] psig. 2

                                                                 < [40.77 kg/cm G (580 psig)]     receiver may vary depending on 2

and [8.78 kg/cm G (125 psig)]. manufacturers recommendations. However, the pressure of 580 psig is the value that has been validated to be an actual one through long-term applications in local nuclear plants. KEPCO & KHNP 164

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) SURVEILLANCE SURVEILLANCE See III.4.2.3. SR 3.8.3.4 SR 3.8.3.4 The air pressure of starting air Verify each DG air start receiver Verify each EDG air start receiver receiver may vary depending on 2 pressure is [225] psig. pressure is [40.77 kg/cm G manufacturers (580 psig)]. recommendations. However, the pressure of 580 psig is the value that has been validated to be an actual one through long-term applications in local nuclear plants. 3.8.4 DC Sources - REQUIRED ACTION REQUIRED ACTION See II.3.3 Operating D.2 --------------NOTE-------------- D.2 None LCO 3.0.4.a is not applicable when entering MODE 4. Be in MODE 4. Be in MODE 5. SURVEILLANCE SURVEILLANCE See III.4.2.3. SR 3.8.4.2 SR 3.8.4.2 Verify each battery charger Verify battery chargers A and B supplies [400] amps at supply 700 amps and battery greater than or equal to the chargers C and D supply 1,200 minimum established float voltage amps at greater than or equal to for [8] hours. the minimum established float voltage for 8 hours. 3.8.5 DC Sources - LCO 3.8.5 LCO 3.8.5 [recently] irradiated Shutdown [One DC electrical power None changed to subsystem shall be OPERABLE.] irradiated.

                         -------REVIEWERS NOTE----------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required KEPCO & KHNP 165

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) only one DC electrical power subsystem to be OPERABLE. Action A and the bracketed optional wording in Condition B are also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions. APPLICABILITY APPLICABILITY During movement of [recently] During movement of irradiated fuel irradiated fuel assemblies. assemblies. 3.8.6 Battery - Same as NUREG-1432 Train A and Train B Parameters electrical power Subsystem changed to Division I and Division II. Some editorial differences have been introduced in CONDITIONS A, C, and F. 3.8.7 Inverters - REQUIRED ACTION REQUIRED ACTION See II.3.3 Train A and Train B Operating B.2 --------------NOTE-------------- B.2 None changed to LCO 3.0.4.a is not applicable Division I and when entering MODE 4. Division II.

                               ------------------------------------                                                                     In addition to the change from Train Be in MODE 4.                            Be in MODE 5.                                                   A and B to Division I and Division II, the LCO was modified to KEPCO & KHNP                                                                                                                                               166

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) specify the number of inverters that are required. 3.8.8 Inverters - LCO 3.8.8 LCO 3.8.8 [recently] irradiated Shutdown [One] inverter[s] shall be None changed to OPERABLE.] irradiated.

                         -------REVIEWERS NOTE----------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]" optional wording in Condition A is also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions. APPLICABILITY APPLICABILITY During movement of [recently] During movement of irradiated fuel irradiated fuel assemblies. assemblies. 3.8.9 Distribution - Same as NUREG-1432 Train A and Train B Systems - Operating changed to Division I and Division II 3.8.10 Distribution APPLICABILITY APPLICABILITY [recently] irradiated Systems - Shutdown During movement of [recently] During movement of irradiated fuel changed to irradiated fuel assemblies. assemblies. irradiated. 3.9 REFUELING OPERATIONS KEPCO & KHNP 167

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 3.9.1 Boron - Same as NUREG-1432 Refueling cavity Concentration changed to refueling pool 3.9.2 Nuclear LCO 3.9.2 LCO 3.9.2 SRM changed to Instrumentation Two source range monitors Two startup channels of the startup channels of (SRMs) shall be OPERABLE. Ex-core Neutron Flux Monitoring ENFMS System (ENFMS) shall be OPERABLE. 3.9.3 Containment LCO 3.9.3 LCO 3.9.3 Penetrations --------------NOTE-------------- None Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls. APPLICABILITY APPLICABILITY None During CORE ALTERATIONS, During movement of [recently] During movement of irradiated fuel irradiated fuel assemblies within assemblies within containment. containment. REQUIRED ACTION REQUIRED ACTION None A.1 Suspend CORE ALTERATIONS. AND A.1 Suspend movement of recently A.2 Suspend movement of irradiated fuel assemblies irradiated fuel assemblies within containment. within containment. SURVEILLANCE SURVEILLANCE SR 3.9.3.2 SR 3.9.3.2

                         -------------NOTE--------------           None KEPCO & KHNP                                                                                                                                 168

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.3.c.1. FREQUENCY FREQUENCY Conservative surveillance SR 3.9.3.1 SR 3.9.3.1 frequency is used in APR1400. None Within 100 hours prior to the start of movement of irradiated fuel within containment AND 7 days Once per 7 days during CORE ALTERATIONS or movement of irradiated fuel within containment 3.9.4 Shutdown Cooling REQUIRED ACTION REQUIRED ACTION (SDC) and Coolant A.4 Close equipment hatch and A.4 Place the containment building Details about actions of For better Circulation - High secure with [four] bolts. penetrations in the required containment building coordination Water Level status as specified in penetrations exist in LCO 3.6.7. between TS 3.9.4 LCO 3.6.7. Therefore Required Action A.4 and TS 3.6.7, the refers to LCO 3.6.7. required action is AND None described briefly. A.5 Close one door in each air lock. AND A.6.1 Close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent. KEPCO & KHNP 169

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) OR A.6.2 Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. SURVEILLANCE SURVEILLANCE The flow rate is specific for The flow rate is SR 3.9.4.1 Verify one SCS loop is SR 3.9.4.1 Verify one SC train is in APR1400. The flow rate for specific for in operation and circulating operation and circulating decay heat removal, boron APR1400. reactor coolant at a flow rate of reactor coolant at a flow rate of mixing and prevention of boron [2200] gpm. 15,710 L/min (4,150 gpm). stratification is evaluated and specified. SURVEILLANCE SURVEILLANCE TSTF-523 (Managing Gas None SR 3.9.4.2 Verify required SC train Accumulation) is applied to piping locations susceptible to APR1400 Technical gas accumulation are Specification. sufficiently filled with water. 3.9.5 Shutdown Cooling LCO 3.9.5 LCO 3.9.5 (SDC) and Two SDC loops shall be The heat removal system shall be 1. For item 'a', the intent of Coolant OPERABLE, and one SDC loop in the following status: APR1400 is the same as that Circulation - Low shall be in operation. of NUREG-1432. Water Level ----------------NOTES---------------- a. Two shutdown cooling (SC)

1. All SDC pumps may be removed trains shall be OPERABLE and 2. For item 'b', APR1400 is more from operation for 15 minutes one SC train shall be in conservative. This ensures two when switching from one train to operation. forced circulation loops are another provided: available for decay heat removal
a. The core outlet temperature b. When Reactor Coolant System if the operating SC pump is maintained >10 degrees F (RCS) level is < 38.72 m (127 ft becomes inoperable for any below saturation 1/4 in), the containment spray reason and improves a reliability temperature, pump in the same electrical of SC operation during reduced
b. No operations are permitted division as an operating SC inventory operation.

that would cause train shall be OPERABLE. introduction of coolant into the Reactor Coolant System with boron concentration KEPCO & KHNP 170

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) less than that required to meet the minimum required boron concentration of LCO 3.9.1, and

c. No draining operations to further reduce RCS water volume are permitted.
2. One required SDC loop may be inoperable for up to 2 hours for surveillance testing, provided that the other SDC loop is OPERABLE and in operation.

CONDITION CONDITION B. No SDC loop OPERABLE or in B. Two SC trains inoperable. operation. OR No SC train in operation. REQUIRED ACTION REQUIRED ACTION This enhances safety and . prevents boron dilution event B.3 Close equipment hatch B.3 Initiate action to raise RCS during reduced inventory and secure with [four] bolts. level to 38.72 m (127 ft operation. 1/4 in). AND Details about actions of AND containment building B.4 Close one door in each air lock. penetrations exist in LCO 3.6.7. B.4 Place the containment building Therefore Required Action B.4 AND penetrations in the required refers to LCO 3.6.7. status as specified in B.5.1 Close each LCO 3.6.7. penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation KEPCO & KHNP 171

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) valve, blind flange, or equivalent. OR B.5.2 Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System. CONDITION CONDITION None C. Containment spray pump in the See III.5.2.3 same electrical division as an operating SC train inoperable with RCS level < 38.72 m (127 ft 1/4 in). REQUIRED ACTION REQUIRED ACTION None C.1 If the containment spray pump See III.5.2.3 in the same electrical division as the alternate SC train is OPERABLE, initiate action to place the alternate SC train in operation. COMPLETION TIME Immediately AND REQUIRED ACTION C.2 Monitor SC System performance. COMPLETION TIME Every 30 minutes AND KEPCO & KHNP 172

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) REQUIRED ACTION C.3 Restore containment spray pump to OPERABLE status. COMPLETION TIME 48 hours CONDITION CONDITION None D. Required Action and associated See III.5.2.3 Completion Time of Required Action C.3 not met. REQUIRED ACTION REQUIRED ACTION None D.1 Raise RCS level to 38.72 m This places the plant in a (127 ft 1/4 in). conservative position with respect to providing decay heat COMPLETION TIME removal. 6 hours SURVEILLANCE SURVEILLANCE This flow value is established to An explicit SR 3.9.5.1 SR 3.9.5.1 ensure adequate decay heat numerical value for Verify required SDC loops are Verify required SC trains are removal and to prevent boron SC pump flow is OPERABLE and one SDC loop is OPERABLE and one SC train is in mixing and also to address the added. in operation. operation with circulating reactor air ingestion in the hot leg when coolant at a flow rate of 15,709 the RCS water inventory is L/min (4,150 gpm) at RCS level maintained at the lowest 38.72 m (127 ft 1/4 in) or permitted level on 14,385 L/min (3,800 gpm) and safety/accident analysis.

                                                         < 15,710 L/min (4,150 gpm) at RCS level < 38.72 m (127 ft 1/4 in).

None SR 3.9.5.3 Verify correct breaker alignment This ensures forced circulation is and indicated power available to available for decay heat removal the required CS pump. if the operating SC pump becomes inoperable for any FREQUENCY reason and improves a reliability 24 hours at RCS level < 38.72 m of SC operation during reduced (127 ft 1/4 in) inventory operation. KEPCO & KHNP 173

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) None SR 3.9.5.4 TSTF-523 (Managing Gas Verify required SC train piping Accumulation) is applied to TSTF-523 is locations susceptible to gas APR1400 Technical incorporated. accumulation are sufficiently filled Specification. with water. FREQUENCY 31 days

3.9.6 APPLICABILITY

APPLICABILITY: Refueling Water Level None During CORE ALTERATIONS, See II.2.1 except during latching and unlatching of control rod drive shafts, During movement of [recently] During movement of irradiated fuel See III.5.2.4 irradiated fuel assemblies within assemblies within containment. containment. REQUIRED ACTION REQUIRED ACTION None A.1 Suspend CORE See II.2.1 ALTERATIONS. AND A.1 Suspend movement of A.2 Suspend movement of [recently] irradiated fuel irradiated fuel assemblies See III.5.2.4 assemblies within containment. within containment. None AND A.3 Initiate actions to restore refueling water level to within See III.5.2.4 limits. Addition None LCO 3.9.7 This operating restriction is an Related ACTIONS

 - Unborated Water                                           The CV-186 valve used to isolate     assumption of initial condition for and Source Isolation Valve -                                     unborated water sources shall be     safety analysis as described in     SURVEILLANCE MODE 6                                                       secured in the closed position.      the APR1400 DCD Tier 2,             REQUIREMENTS KEPCO & KHNP                                                                                                                                         174

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Section 15.4.6. are added. APPLICABILITY MODE 6 Addition None LCO 3.9.8 Related ACTIONS

 - Decay Time                                                 The reactor shall be subcritical for                                    and 100 hours.                                                            SURVEILLANCE REQUIREMENTS APPLICABILITY                                                           are added.

During movement of irradiated fuel assemblies in the reactor pressure vessel. 4.0 DESIGN FEATURES 4.1 Site Location - Same as NUREG-1432 4.2 Reactor Core 4.2.1 4.2.1 The items reflect APR1400 The reactor shall contain [217] fuel The reactor shall contain 241 fuel design. assemblies. Each assembly shall assemblies. Each assembly shall consist of a matrix of [Zircalloy or consist of a matrix of zirconium alloy ZIRLO] fuel rods with an initial clad fuel rods with an initial composition of natural or slightly composition of natural or slightly enriched uranium dioxide (UO2) as enriched uranium dioxide (UO2) as fuel material. fuel material. 4.2.2 4.2.2 The items reflect APR1400 The reactor core shall contain [91] The reactor core shall contain 81 full design. control element assemblies strength and 12 part strength control (CEAs). The control material shall element assemblies (CEAs). The be [silver indium cadmium, boron control material of full strength and carbide, or hafnium metal] as part strength CEAs shall be boron approved by the NRC. carbide and Inconel Alloy 625, respectively. 4.3 Fuel Storage 4.3.1.1 4.3.1.1 4.3.1.1

a. Fuel assemblies having a a. Fuel assemblies having a a. The item is specific for maximum U-235 enrichment of maximum U-235 enrichment of APR1400 design.

[4.5] weight percent, 5 weight percent; (DCD Tier 2, Section 9.1.1)

b. Keff 0.95 if fully flooded with b. keff < 1.0 if flooded with b. This change is to incorporate KEPCO & KHNP 175

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) unborated water, which includes unborated water and keff 0.95 if SRP 9.1.1 Rev. 3. an allowance for uncertainties as flooded with water borated to (DCD Tier 2, Section 9.1.1) described in [Section 9.1 of the 1231 ppm enriched, which FSAR], includes an allowance for uncertainties; [c. A nominal [9] inch center to c. A nominal (27.5 cm (10.83 in)) c. Based on the result of the center distance between fuel center-to-center distance criticality analysis and the assemblies placed in [the high between fuel assemblies placed detailed design of the fuel density fuel storage racks], ] in Region I of the spent fuel storage racks for APR1400. storage racks; [d. A nominal [10.4] inch center to d. A nominal (22.5 cm (8.86 in)) d. Based on the result of the center distance between fuel center-to-center distance criticality analysis and the assemblies placed in [the low between fuel assemblies placed detailed design of the fuel density fuel storage racks], ] in Region II of the spent fuel storage racks for APR1400. storage racks; [ e. New or partially spent fuel e. Fuel assemblies with a assemblies with a discharge discharge burnup in the burnup in the acceptable range "acceptable domain" of Figure of Figure [3.7.18-1] may be 3.7.16-1 may be allowed allowed unrestricted storage in unrestricted storage in Region I [either] fuel storage rack(s), and ] or Region II of Figure 4.3-1; and [f. New or partially spent fuel f. New or partially spent fuel f. Refer to the response to assemblies with a discharge assemblies with a discharge RAI 12-7977, Question 16-24, burnup in the "unacceptable burnup in the "unacceptable Item 14. range" of Figure [3.7.18-1] will be domain" of Figure 3.7.16-1 shall stored in compliance with the be stored only in Region I of NRC approved [specific Figure 4.3-1. document containing the analytical methods, title, date, or specific configuration or figure].] 4.3.1.2 4.3.1.2 4.3.1.2

a. Fuel assemblies having a a. Fuel assemblies having a a. The item is specific for maximum U-235 enrichment of maximum U-235 enrichment of APR1400 design.

[4.5] weight percent, 5 weight percent; (DCD Tier 2, Section 9.1.1)

b. Keff 0.98 if fully flooded with b. keff 0.95 if fully flooded with b. APR1400 criterion is more KEPCO & KHNP 176

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) unborated water, which includes unborated water, or mist, which conservative than that of an allowance for uncertainties as includes an allowance for NUREG-1432. described in [Section 9.1 of the uncertainties as described in (DCD Tier 2, Section 9.1.1) FSAR], FSAR Section 9.1 Fuel Storage and Handling.;

d. A nominal [10] inch center to d. A nominal center-to-center d. Based on the result of the center distance between fuel distance between fuel criticality analysis and the assemblies placed in the storage assemblies placed in the new detailed design of the fuel racks. fuel storage racks of 35.5 cm storage racks for APR1400.

(14 in). 4.3.2 4.3.2 The spent fuel storage pool is The spent fuel pool is designed and designed and shall be maintained shall be maintained to prevent to prevent inadvertent draining of inadvertent draining of the pool the pool below elevation [23 ft]. below a water level of 7 m (23 ft) above the top of the spent fuel storage rack. 4.3.3 4.3.3 4.3.3 The item is specific for APR1400 The spent fuel pool is designed and The spent fuel pool is designed and design. shall be maintained with a storage shall be maintained with a storage (DCD Tier 2, Section 9.1.1) capacity limited to no more than capacity limited to no more than [1542] fuel assemblies. 1,792 fuel assemblies. Figure is added for 4.3.1.1.e. and None Figure 4.3-1 4.3.1.1.f. 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility - Same as NUREG-1432 5.2 Organization - Same as NUREG-1432 5.3 Unit Staff - Same as NUREG-1432 Qualifications 5.4 Procedures - Same as NUREG-1432 KEPCO & KHNP 177

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) 5.5 Programs and 5.5.2 Primary Coolant Sources 5.5.2 Primary Coolant Sources APR1400 design characteristics Manuals Outside Containment Outside Containment are reflected. The systems include [Low The systems include Containment Pressure Injection, Reactor Spray System, Safety Injection Building Spray, Makeup and System, Chemical and Volume Purification, and Hydrogen Control System, Gaseous Waste Recombiner]. Management System and Containment Hydrogen Control System. 5.5.9 Steam Generator (SG) 5.5.9 Steam Generator (SG) APR1400 design characteristics Plugging, not repair, Program Program are reflected. is specified for APR1400. b.2. ~ Leakage is not to exceed b.2. ~ Leakage is not to exceed APR1400 doesnt have a repair Operational [1 gpm] per SG. 1.14 L/min (0.3 gpm) per SG. method approved by NRC. leakage is specified in LCO 3.4.12 for 5.5.9.d.1 5.5.9.d.1 TSTF-510 Rev. 2 (Revision to APR1400. Inspect 100% of the tubes in each Inspect 100% of the tubes in each Steam Generator Program Alternate tube SG during the first refueling outage SG during the first refueling outage Inspection Frequencies and repair criteria are following SG replacement. following SG installation. Tube Sample Selection) is not listed. applied to APR1400 NRC DC 5.5.9.d.2 5.5.9.d.2 Technical Specifications. Inspection [Inspect 100% of the tubes at After the first refueling outage sequential periods of 60 effective following SG installation, inspect descriptions differ. full power months. The first each SG at least every 72 effective sequential period shall be full power months or at least every considered to begin after the first third refueling outage (whichever inservice inspection of the SGs. No results in more frequent SG shall operate for more than 24 inspections). In addition, the effective full power months or one minimum number of tubes refueling outage (whichever is less) inspected at each scheduled without being inspected.] inspection shall be the number of tubes in all SGs divided by the Inspect 100% of the tubes at number of SG inspection outages sequential periods of 120, 90, and, scheduled in each inspection thereafter, 60 effective full power period as defined in a, b, c and d months. The first sequential period below. If a degradation KEPCO & KHNP 178

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) shall be considered to begin after assessment indicates the potential the first inservice inspection of the for a type of degradation to occur SGs. In addition, inspect 50% of at a location not previously the tubes by the refueling outage inspected with a technique capable nearest the midpoint of the period of detecting this type of and the remaining 50% by the degradation at this location and refueling outage nearest the end of that may satisfy the applicable tube the period. No SG shall operate for plugging criteria, the minimum more than 48 effective full power number of locations inspected with months or two refueling outages such a capable inspection (whichever is less) without being technique during the remainder of inspected.] the inspection period may be prorated. The fraction of locations Inspect 100% of the tubes at to be inspected for this potential sequential periods of 144, 108, 72, type of degradation at this location and, thereafter, 60 effective full at the end of the inspection period power months. The first sequential shall be no less than the ratio of period shall be considered to begin the number of times the SG is after the first inservice inspection of scheduled to be inspected in the the SGs. In addition, inspect 50% inspection period after the of the tubes by the refueling outage determination that a new form of nearest the midpoint of the period degradation could potentially be and the remaining 50% by the occurring at this location divided by refueling outage nearest the end of the total number of times the SG is the period. No SG shall operate for scheduled to be inspected in the more than 72 effective full power inspection period. Each inspection months or three refueling outages period defined below may be (whichever is less) without being extended up to 3 effective full inspected.] power months to include a SG inspection outage in an inspection period and the subsequent inspection period begins at the conclusion of the included SG inspection outage. a) After the first refueling outage following SG installation, inspect 100% of the tubes KEPCO & KHNP 179

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) during the next 144 effective full power months. This constitutes the first inspection period; b) During the next 120 effective full power months, inspect 100% of the tubes. This constitutes the second inspection period; c) During the next 96 effective full power months, inspect 100% of the tubes. This constitutes the third inspection period; and d) During the remaining life of the SGs, inspect 100% of the tubes every 72 effective full power months. This constitutes the fourth and subsequent inspection periods. 5.5.9.d.3 5.5.9.d.3

                         ~(whichever is less)              ~(whichever results in more frequent inspections) 5.5.9.f                           None Provisions for SG tube repair methods.

[etc.] 5.5.16 5.5.16

b. The calculated peak b. The calculated peak containment internal pressure containment internal pressure for the design basis loss of for the design basis loss of coolant accident, Pa is [45 coolant accident, Pa is 2

psig]. The containment design 3.60 kg/cm G (51.21 psig). The KEPCO & KHNP 180

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) pressure is [50 psig]. containment design pressure is 60 psig.

c. The maximum allowable c. The maximum allowable containment leakage rate, La, at containment leakage rate, La at Pa, shall be [ ]% of containment Pa, shall be 0.1% of air weight per day. containment air weight per day.

5.5.19 5.5.19 None f. The difference between the instrument channel trip setting as-found value and the previously recorded as-left value for each Technical Specification required automatic protection instrumentation function shall be trended and evaluated to verify that the instrument channel is functioning in accordance with its design basis. None g. The program shall establish a document containing the current value of the specified NTSP, AV, AFT, and ALT for each Technical Specification required automatic protection instrumentation function and references to the calculation documentation. Changes to this document shall be governed by the regulatory requirement of 10 CFR 50.59. In addition, changes to the specified NTSP, AV, AFT, and ALT values shall be governed by the approved setpoint methodology. This document, including any KEPCO & KHNP 181

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) revisions or supplements, shall be provided upon issuance to the NRC. 5.5.20 [ Surveillance Frequency None The Surveillance Frequency Control Program Control Program of the NUREG-1432 has not been applied to the APR1400 plants. 5.6 Reporting 5.6.3 CORE OPERATING LIMITS 5.6.3 CORE OPERATING LIMITS Requirements REPORT REPORT

                         -------REVIEWERS NOTE-----------             None Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the Topical Report, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No:

ML110660285 for details. 5.6.4 RCS Pressure and 5.6.4 Reactor Coolant System Temperature Limits Report (RCS) PRESSURE AND 2 changed to 2 TEMPERATURE LIMITS REPORT (PTLR)

                         -------REVIEWERS NOTE-----------             None Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list KEPCO & KHNP                                                                                                                                              182

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) the number and title of the Topical Report, and the PTLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the PTLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

3. Low Temperature Overpressure 3. Low Temperature Overpressure Protection (LTOP) System lift Protection (LTOP) System lift setting limits for the Power setting limits for the Pilot Operated Relief Valves Operated Safety Relief Valves (PORVs), developed using (POSRVs), developed using NRC approved methodologies NRC approved methodologies may be included in the PTLR. may be included in the PTLR.
7. 7.
                         ~where the predicted increase in              ~where the predicted increase in RTNDT is based on the mean shift in           RTNDT is based on the mean shift in RTNDT plus the two standard                   RTNDT plus the two standard deviation value (2) specified in            deviation value (2) specified in Regulatory Guide 1.99, Revision 2.            Regulatory Guide 1.99, Revision 2.

If the measured value exceeds the If the measured value exceeds the predicted value (increase in RTNDT predicted value (increase in RTNDT

                         + 2),                                       + 2),

5.6.5 Post Accident Monitoring 5.6.5 Accident Monitoring Report The name for the Report instrumentation is changed according to RG 1.97 Rev. 4. When a report is required by When a report is required by Condition B or F of LCO 3.3.[11], Condition B or F of LCO 3.3.11, "Post Accident Monitoring (PAM) "Accident Monitoring KEPCO & KHNP 183

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 Number Standard APR1400 (NUREG-1432 Technical Specifications Technical Specifications Justification Remark Contents) (NUREG-1432, Rev. 4) (Rev. 3) Instrumentation, Instrumentation (AMI), 5.6.7 Steam Generator Tube 5.6.7 Steam Generator Tube Inspection Report Inspection Report TSTF-510 Rev. 2 (Revision to Steam Generator Program

b. Active degradation mechanisms b. Degradation mechanisms found, Inspection Frequencies and found, Tube Sample Selection) is
d. Location, orientation (if linear), applied to APR1400 NRC DCD Indications changed
d. Location, orientation (if linear), and measured sizes (if Technical Specifications. to degradations and measured sizes (if available) of service induced available) of service induced indications, indications,
f. The number and percentage of
f. Total number and percentage of tubes plugged to date, and the tubes plugged [or repaired] to effective plugging percentage in date, each steam generator, and NUREG-1432 5.6.7.f. and h.

combined into f. for APR1400. [h. The effective plugging None percentage for all plugging [and tube repairs] in each SG, and] [i. Repair method utilized and the None number of tubes repaired by each repair method.] 5.7 High Radiation Area - Same as NUREG-1432 KEPCO & KHNP 184

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 IV. CONCLUSIONS The APR1400 Technical Specifications satisfy 10 CFR 50.36, Technical specifications. The APR1400 Technical Specifications are compared with NUREG-1432, Rev. 4.0, and the justifications for the deviations from NUREG-1432 are described in this report. KEPCO & KHNP 185

Deviation Report between NUREG-1432 Rev. 4.0 and APR1400 Technical Specifications APR1400-K-O-NR-14001-NP, Rev. 3 V. REFERENCES [1] Title 10 Code of Federal Regulations Part 50.36, Technical Specifications [2] NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Vol. 1, Rev. 4.0, April 2012 [3] NUREG-0800, Branch Technical Position 5-4, Design Requirements of the Residual Heat Removal System, Rev. 4.0, March 2007 [4] NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev. 4.0, December 2010 [5] WCAP-16364-NP, Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422), Rev. 2.0, May 2010 [6] NRC RG 1.97, Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, Rev. 4.0, June 2006 [7] NUREG-0800, 9.1.1 Criticality Safety of Fresh and Spent Fuel Storage and Handling, Rev. 3.0, March 2007 KEPCO & KHNP 186}}