Text

Application to Revise Technical Specifications to Adopt TSTF -529. Clarify Use and Application Rules
	ML17227A172
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	08/11/2017
From:	Harden P; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-17-108, TSTF-529
	Download: ML17227A172 (77)
	v • d • e

FENOG n r$ Ene,8f l*rclar @ati tg Cunp ny 341 Whrte Pond Drive Akron, Ohio 44320 Paul A. Harden Senror Vice President and Chief Operating Offrcer August 11, 2017 L-1 7-1 08 10 cFR 50.90 ATTN. Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Aoolication to Revise Technical Soecifications to Adopt TSTF -529. "CIarifu Use and Application Rules" Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the Technical Specifications for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP).

The proposed amendment would modify Technical Specification (TS) requirements in Section 1.3 and Section 3.0 regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4.

Enclosure A provides a description and assessment of the proposed changes.

Enclosure B provides the existing TS pages marked up to show the proposed changes.

Enclosure C provides revised (clean) TS pages.

Enclosure D provides, for information only, existing TS Bases pages marked to show the proposed changes.

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-17-108 Page 2 Approval of the proposed amendment is requested by August 31, 2018. Once approved, the amendment shall be implemented within 90 days.

There are no regulatory commitments contained in this letter. lf there are any questions, or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - FIeet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August // , 2017.

Since Paul A Harden

Enclosures:

A. Description and Assessment of License Amendment Request to Adopt TSTF-529 B. BVPS, DBNPS, and PNPP Proposed Technical Specification Changes (Mark-Up)

C. BVPS, DBNPS, and PNPP Revised Technical Specification Pages D. BVPS, DBNPS, and PNPP Proposed Technical Specification Bases Changes (Mark-Up)

CC NRC Region I Administrator NRC Region lll Administrator NRC Resident lnspector (BVPS)

NRC Resident Inspector (DBNPS)

NRC Resident lnspector (PNPP)

NRR Project Manager (Fleet)

Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Enclosure A L-1 7-1 08 Description and Assessment of License Amendment Request to Adopt TSTF-529 (3 pages follow)

Description and Assessment of License Amendment Request to Adopt TSTF-529 Page 1 of 3

1.0 DESCRIPTION

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

a Section 1.3 is revised to clarify "discovery."

e Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

t Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

a Surveillance Requirement (SR) 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.

2.0 ASSESSMENT 2.1 Aoolicabilitv of Evaluation FENOC has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-529. As described in the subsequent paragraphs, FENOC has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP) and justify this amendment for the incorporation of the changes to the BVPS, DBNPS, and PNPP TSs.

2.2 Variations For BVPS and PNPP, FENOC is not proposing any variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staff's safety evaluation dated April 21,2016.

For DBNPS, FENOC is proposing the following variation from the TS changes described in the TSTF-529, but is not proposing any variations from the applicable parts of the NRC staff's safety evaluation dated April 21, 2016.

Page 2 of 3 The proposed change described in TSTF-529 for TS LCO 3.0.4.b for generic Babcock &

Wilcox STS places the statement regarding exceptions in parenthesis and replaces the ending comma with a semicolon. For DBNPS, the ending semicolon was implemented in an earlier amendment, and, therefore, requires no further modification to meet the changes described in TSTF-529. This variation does not affect the applicability of TSTF-529 or the NRC staff's safety evaluation to the proposed license amendment.

One difference from the proposed TS Bases changes described in TSTF-529 should be noted for BVPS and PNPP. Under the TS Bases section LCO 3.0.4, TSTF-529 proposes changing the specifications typically applied to LCO 3.0.4.c from (e.9.,

Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient) to (e.9., RCS Specific Activity). This specific change was implemented previously at BVPS and PNPP, and, therefore, requires no further modification to the TS Bases for these plants to be consistent with the changes described in TSTF-529.

3.0 REGULATORY ANALYSIS

3.1 No Siqnificant Hazards Consideration Analvsis FENOC requests adoption of TSTF-529, "Clarify Use and Application Rules," that is an approved change to the standard technical specifications (STS), into the BVPS, DBNPS, and PNPP technical specificatiqns (TS). The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3.

Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the staft of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3,0.3 when an SR has not been previously performed FENOC has evaluated whether or not a signiflcant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment," as discussed below:

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

Response: No.

The proposed changes to Section 1,3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed change does not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Page 3 of 3 Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change clarifies the application of Section 1 .3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

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

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

Enclosure B L-17-108 BVPS, DBNPS, and PNPP Proposed Technical Specification Changes (Mark-Up)

(13 pages follow)

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the time ef discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time besins when a senior licensed operator on the operating shift crew with responsibilitv for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise snecified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testins. without starting the Completion Time. While utilizins the Note, should a Qondition be applicable for anv reason not addressed by the Note. the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time besins at that point. The exceptions mav also be incorporated into the Comp.letion Time. For examnle. LCO 3.8.1. "AC Sources - Ooeratino." Reouired Action 8.2.

requires declarinq required feature(s) supported bv an inoperable diesel generator. inoperable when the redundant required feature(s) are inonerable. The Comnletion Time states. "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discoverv of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not beqin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no Ionger exists or the unit is not within the LCO Applicability.

lf situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef discovery of the situation that required entry into the Condition. unless othenruise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless othenruise p,pgcifigd.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperabi lity:

a Must exist concurrent with the first inoperability and Beaver Valley Units 1 and 2 1.3-1 Amendments Z7A I rc1

LCO Applicability 3.0 3.0 LTMTTTNG CONDITTON FOR OPERATTON (LCO) APPLTCABTLlTY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

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

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

LCO 3.0.3 \It'hen an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:

a. MODE3withinThours,

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months Exceptions to this Specification are stated in the individual Specifications.

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

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

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a \I/hen the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate+ {exceptions to this Specification are stated in the individual Specificationsfi or Beaver Valley Units 1 and 2 3.0-1 Amendments 27+^ I 16?.

SR Applicability 3.0 3.0 SURVETLLANCEREQUTREMENT(SR)APPLTCABTLITY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surueillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

sR 3.0.2 The specified Frequency for each SR is met if the Surveillance is pedormed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each pefformance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

sR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up lo24 hours or up to the Iimit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is onlv applicable when there is a reasonable expectation the surveillance will be met when oerformed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

lf the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

VUlren the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

sR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. \Mren an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

Beaver Valley Units 1 and 2 3.0-4 Amendments Z74l 162 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the time ef discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless othenrulse specified. the Completion Time begins when a senior Iicensed operator on the operatinq shift crew with responsibilitv for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "othenruise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform,specific tasks, such as testino. without startino the Comoletion Time. While utilizino the Note.

should a Condition be applicable for anv reason not addressed bv the Note, the Completion Time begins. Should the time allowance in the Note..b-9.-e{qqeded. the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For examnle. LCO 3.8.1. "AC Sources - Operatino." Reouired Action 8.2.

requires declarino required feature(s) supported bv an inoperable diesel oenerator. inoperable when the redundant reouired feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperabilitv of redundant required feature(s)." In this case the Completion Time does not beoin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

!f situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef Davis-Besse 1.3-1 Amendmsnl 279

Completion Times 1.3 discovery of the situation that required entry into the Condition. unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within Iimits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition . unless othenruise specified.

However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subseq uent inoperabi lity:

a Must exist concurrent with the first inoperability; and b Must remain inoperable or not within Iimits after the first inoperability is resolved.

Davis-Besse 1.3-1 Amendmgn{ 279

LCO Applicability 3.0 3.0 LTMITING CONDITTON FOR OPERATTON (LCO) APPLTCABTLTTY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

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

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:

a. MODE3withinThours;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and C. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

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

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

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. VUhen the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriatq (exceptions to this Specification are stated in the individual Specifications); or Davis-Besse 3.0-1 Amendmsnf 279

SR Applicability 3.0 3.0 SURVETLLANCE REQUTREMENT (SR) APPLTCABTLTTY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between pedormances of the Surveillance, shall be failure to meet the LCO. Failure to pefform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

sR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

sR 3.0.3 lf it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. Th,e delav period is onlv applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be peformed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

lf the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Wren the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

sR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. \trShen an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

Davis-Besse 3.0-4 Amendment 27$

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the time ef discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion time beqins when a senior licensed operator on the operatinq shift crew with responsibilitv for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as feqtinn r,vithnr rt qtertino the Co m nlctinn m A Wh ile uti Iizi nfl th E Note should a Condition be applicable for anv reason not addressed by the Note, the Completion Time beqins. Should the time allowance in the Note be exceded. the Completion Time beqins at that point. The exceptions mav also be incorporated into the Completion Time. For crramnle l(-.(138 1 "AC Sor rrncq - Oncratinn " Ren uired Action 8.2 requires declaring required feature(s) supported bv an inoperable diesel qenerator. inoperable when the redundant reouired feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." ln this case the Completion Time does not beqin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

lf situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be pedormed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the tirne ef discovery of the situation that required entry into the Condition. unless othenrvise specified.

PERRY - UNIT 1 1.0-11 Amendment No. 69

Completion Times 1.3 Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Cond ition . unless othenruise specified.

(continued)

PERRY - UNIT 1 1.0-1 1 Amendment No. 69

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate, (exceptions to this Specification are stated in the individual Specificationst[ or

c. VUhen an allowance is stated in the individual value, parameter, or other Specification.

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

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

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. ln this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." lf a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the Ioss of safety function exists are required to be entered.

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

(continued)

PERRY - UNIT 1 3.0-2 Amendment No. 4#l

SR Applicability 3.0 3.0 SURVEILLANGE REQUIREMENT (SR) APPLICABILITY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be pefformed on inoperable equipment or variables outside specified Iimits.

sR 3.O.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

sR 3.0.3 lf it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LGO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delav period is onlv applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

lf the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

\IUhen the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

PERRY - UNIT 1 3.0-4 Amendment No. {*5

Enclosure C L-17-108 BVPS, DBNPS, and PNPP Revised Technical Specification Pages (17 pages follow)

lnformation Only Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior Iicensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "othenuise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LGO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time States, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." ln this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

lf situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Beaver Valley Units 1 and 2 1.3- 1 Amendments I

Completion Times 1.3 1.3 Completion Times DESCRI PTION (continued)

Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Gompletion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within Iimits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subseq uent inoperability:

a. Must exist concurrent with the first inoperability and

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

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

a The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or C. The stated Completion Time as measured from discovery of the su bsequent i noperability.

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

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified Beaver Valley Units 1 and 2 1.3-2 Amendments I

Completion Times lnformation Only 1.3 1.3 Completion Times DESCRI PTI ON (continued) by the phrase "from discovery . . ." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion AND Time not met.

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

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

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

Beaver Valley Units 1 and 2 1.3 - 3 Amendments I

LGO Applicability lnformation Only 3.0 3.0 LtMtTING CONDlTTON FOR OPERATTON (LCO) APPLTCABTLTTY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

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

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated AGTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:

a. MODE3withinThours,

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and C. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications

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

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

LCO 3.0.4 \It'hen an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a \I/hen the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or Beaver Valley Units 1 and 2 3.0-1 Amendments I

SR Applicability lnformation Only 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to pedorm a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

sR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

sR 3.0.3 lf it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up lo 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

lf the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Vt/lT en the Surueillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Beaver Valley Units 1 and 2 3.0-4 Amendments I

SR Applicability lnformation Only 3.0 3.0 SR Applicability sR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. V/hen an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

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

Beaver Valley Units 1 and 2 3.0-5 Amendments I

lnformation Only Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specifo minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LGO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without stailing the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point" The exceptions may also be incorporated into the Gompletion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." ln this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in etfect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Gonditions, separate Davis-Besse 1.3-1 Amendment

lnformation Only Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperabi lity:

a Must exist concurrent with the first inoperability; and b Must remain inoperable or not within limits after the first inoperability is resolved.

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

a The stated Completion Time, as measured from the initial entry into the Condition, plus an additiona! 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or b The stated Completion Time as measured from discovery of the su bsequent i noperabi Iity.

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

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per I hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery . . ."

Davis-Besse 1.3-2 Amendment

lnformation Only Completion Times 1.3 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met 8.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

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

Davis-Besse 1.3-3 Amendment

lnformation Only Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1,3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

\Mren a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions 8.1 and 8.2 start. lf the inoperable pump is restored to OPERABLE status after Condition B is entered, ConditionsA and B are exited, and therefore, the Required Actions of Condition B may be terminated.

\tVhen a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.

\rVhile in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.

On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days.

Davis-Besse 1.3-4 Amendment

lnformation Only LCO Applicability 3.0 3.0 LTMITING CONDTTTON FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

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

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

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

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

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

4.. \Mren the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or Davis-Besse 3.0-1 Amendment

lnformation Only SR Applicability 3.0 3.0 SURVElLLANCE REQUTREMENT (SR) APPLlCABILTTY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwlse stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

sR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications sR 3.0.3 lf it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Wren the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Gondition(s) must be entered.

sR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. \tr/hen an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

Davis-Besse 3.0-4 Amendment

Information Only Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. lt is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "othenrise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. \A/hile utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate (continued)

PERRY - UNIT 1 1,0-1 1 Amendment No

Completion Times lnformation Only 1.3 1.3 Completion Times DESCRIPTION Completion Times are tracked for each Condition starting from the (continued) discovery of the situation that required entry into the Condition, unless othenruise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within Iimits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subseq uent i noperability:

a Must exist concurrent with the first inoperability; and b Must remain inoperable or not within Iimits after the first inoperability is resolved.

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

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

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

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per I hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Gondition entry) or as a time modified by the phrase "from discovery . . ." Example 1.3-3 illustrates one use of (continued)

PERRY - UNIT 1 1 .0-12 Amendment No

lnformation Only Completion Times 1.3 1.3 Completion Times DESCRIPTION this type of Completion Time. The 10 day Completion Time specified for (continued) Conditions A and B in Example 1.3-3 may not be extended.

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3.1 ACTIONS GONDITION REQUIRED ACTION COMPLETION TIME B. Required Action 8.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion AND Time not met.

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

The Required Actions of Condition B are to be in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for reaching MODE 4 from the time that Condition B was entered. lf MODE 3 is reached within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for reaching MODE 4 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

(continued)

PERRY - UNIT 1 1 .0-13 Amendment No.

LCO Applicability lnformation Only 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or c Vt/lren an allowance is stated in the individual value, parameter, or other Specification.

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

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

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. ln this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." lf a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

(continued)

PERRY - UNIT 1 3.0-2 Amendment No

SR Applicability lnformation Only 3.0 3.0 SURVETLLANCE REQUTREMENT (SR) APPLICABILlTY sR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless othenruise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified Iimits.

sR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

lf a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial pedormance.

Exceptions to this Specification are stated in the individual Specifications.

sR 3.0.3 lf it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

lf the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

VUI'ren the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

PERRY - UNIT 1 3.0-4 Amendment No.

Enclosure D L-17-108 BVPS, DBNPS, and PNPP Proposed Technical Specification Bases Changes (Mark-Up)

(38 pages follow)

LCO Applicability lnformation Only B 3.0 B 3.0 LTMtTtNG CONDITlON FOR OPERATTON (LCO) APPLTCABILTTY BASES LCOs LCO 3.0.1 through LCO 3.0"8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LGO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Gompletion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. unless othenruise snecified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time Iimit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. lf this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. !n this case, compliance with the Required Actions provides an acceptable Ievel of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

Beaver Valley Units 1 and 2 83.0-1 Revision 3

LCO Applicability lnformation Only B 3.0 BASES LCO 3.0.3 (continued) warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. lt is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in Iieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, t hour is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrica! generation with the Ioad dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to rehentet lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met,

b. The LCO is no longer applicable.

bg. A Condition exists for which the Required Actions have now been performed, or eel. ACTIONS exist that do not have expired Gompletion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time Iimits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. lf the unit is in a lower MODE of operation when a shutdown is required, the time limit for

@the next lower MODE applies. lf a lower MODE is

@inlesstimethanallowed,however,thetotalallowabIe time to reaehenlgt

lnformation Only Beaver Valley Units 1 and 2 83.0-3 Revision O

LCO Applicability lnformation Only B 3.0 BASES LCO 3.0.3 (continued)

MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is @ in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for

@MoDE4isthenext11hours,becausethetotaltimefor

@MoDE4isnotreducedfromtheallowableIimitof 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to

@IalowerMoDEofoperationinlessthanthetotaItimeaIIowed.

In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3,0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2,3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.15, "Fuel Storage Pool Water Level." LCO 3.7.15 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool and during movement of fuel assemblies over irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. lf the LCO and the Required Actions of LCO 3.7.15 are not met while in MODE 1,2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Actions of LCO 3.7.15 of "Suspend movement of irradiated fuel assemblies in the fuel storage pool and suspend movement of fuel assemblies over irradiated fuel assemblies in the fuel storage pool" are the appropriate Required Actions to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.9., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered pe+mi ollowino entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance

lnformation Only Beaver Valley Units 1 and 2 B3.0-4 Revision e

LCO Applicability lnformation Only B 3.0 BASES LCO 3.0.4 (continued) with that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable Ievel of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made i Applicabilitv.

For example. LCO 3.0.4.a mav be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trin condition within the Comnleti on Time. Transition into a MODE or other specified conditisn in the Applicabilitv mav be made in accordance with LCO 3.0.4 and the channel is subseouentlv olaced in the triooed condition within the.Qompletion Time, which begins when the Applicabilitv is entered. lf the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION ("Required Action and associated Completion Time not m ) allows the OPERABLE train to be placed in operation, use of LCO .0.4.a is acceotable because the SU bseo uent ACTIONS to be ente followino enlrv into lhe IVIODF include ACTIONS (place the OPE E train in ooeration) that permit safe plant operation for al1 gn!!mjte.d.,period of time in the MODE or other qpecified condition to be entered.

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

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4(b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 1 1 of NUMARC 93-01, "lndustry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power PIants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition,

actions to minimize the magnitude of risk increases (establishment of lnformation Only backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

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

Beaver Valley Units 1 and 2 83.0-5 Revision O

LCO Applicability Information Only B 3.0 BASES LCO 3.0.4 (continued)

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

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified Iimits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surueillances that have not been pefformed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within Iimits) and restoring compliance with the affected LCO.

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

a. The OPERABILITY of the equipment being returned to service or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to seruice in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. lf the OPERABILITY of the affected equipment can not be demonstrated, the administrative controls will also ensure the equipmenUplant is restored to the required condition in a timely manner.

This Specification does not provide time to perform any other preventive or corrective maintenance. Minor corrections such as adjustments of limit switches to correct position indication anomalies are considered within the scope of this Specification. .LC_O.3.0.5 should lot be used in lieu of other practicable alternatives that complv with Required Actions and that do not require chanqinq the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstratinq equipment is OPERABLE with the Required Actions not met is openinq a manual valve that was closed to complv with Required Actions to isolate a flowpath with excessive Reactor Coolant Svstem (RCS) Pressure lsolation Valve (PlV) leakage in order to perform testinq to demonstrate that RCS PIV leakaqe is now within limit.

rns

Examples of demonstrating equinmqnt OPERABILITY include instances lnformation Only in which it is necessarv to take an i nerable channel or trio svstem out of a tripped condition that was directed bv a Require{Action. if there is no Required Action Note for tbi$, purpose. An example of verifying OPERABILITY of equipment rem from service is takino a triooed channel out of the trioped conditionlo pFrmit the loqic to function and indicate the approoriate response d rino oerformance of reouired testino on the inoper-able channe!.

@ of demonstrating the OPERABILITY of other equipment isare taking an inoperable channel or trip system out of the tripped conditionll to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system-.p1.4 Beaver Valley Units 1 and 2 83.0-7 Revision O

LCO Applicability lnformation Only B 3.0 BASES LCO 3.0.5 (continued) example ef4emenstrating the OPERnEItITY ef ether equiBment is taking o permit the logic to function and indicate the appropriate response during the pefformance of required testing on another channel in the same trip system.

The administrative controls in LCO 3.0.5 applv in all cases to systems or components in Chapter 3 of the Technical Specifications, as lonq as the testinq could not be conducted while complving with the Required Actions. This includes the realiqnment or repositionino of redundant or alternate equipment or trains previouslv manipulated to complv with ACTIONS, as well as equipment removed from service or declared inoperable to complv with ACTIONS.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable suppoiled system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specifo other Required Actions.

VUlren a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions, However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.1 1, "Safety Function Determination Program (SFDP),"

lnformation Only ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, Beaver Valley Units 1 and 2 83.0-8 Revision O

SR Applicability lnformation Only B 3.0 BASES SR 3.0.2 (continued) 2 years, per Specification 5.5.4.b. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program (per Specification 5.5.12). This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires pefformance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly mere+y o extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

sR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillancehasnotbeen@withinthespecified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time 1s mF{e+eperform Surveillances that have been missed. This delay period permits the ofaSurveillancebeforecomplyingwithRequired Actions or other remedial measures that might preclude of the Surueillance" The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personne!, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surueillance being pefformed is the verification of conformance with the requirements, When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering

Beaver Valley Units 1 and 2 83.0-18 Revision 14 lnformation Only

SR Applicability lnformation Only B 3.0 BASES SR 3.0.3 (continued)

MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance, However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 3.0.3 is onlv applicable if there is a reasonable exnectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.

Manv factors should be considered, such as the period of time since the Surveillance was last performed. or whether the Surveillance. or a portion thereof, has ever been performed, and anv other indications, tests, or activities that miqht support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relav contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relav contact: the adiacent, phvsicallv connected relav contacts were tested durinq the SR performance: the subject relay contact has been tested bv another SR; or historical operation of the subiect relav contact has been successful. lt is not sufficient to infe,r the behavior of the associated equipment from the performance of similar equipment. The rigor of determininq whether there is a reasonable expectation a Surveillance will be met when pedormed should increase based on the Ienqth of time since the last performance of the Surveillance. lf the Surveillance has been performed recentlv. a review of the Surveillance historv and equipment performance mav be sufficient to support a reasonable expectation that the Surveillance will be met when performed.

For Surveillances that have not been performed for a lonq period or that hqve never been performed, a rigorous evaluation based on obiective evidence should provide a hiqh degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledoeable individual to understand the basis for the determination.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used @

to extend Surveillance intervals. \Mrile up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity, The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit

conditions, planning, availability of personnel, and the time required to lnformation Only perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power PIants."

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. lf the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.

lf a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay Beaver Valley Units 1 and 2 83.0-19 Revision 44

lnformation Only LCO Applicability B 3.0 B 3.0 LTMTTING CONDTTTON FOR OPERATION (LCO) AppLrCABrLrTy BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to al! Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. lf this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (\Mrether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. ln this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

Davis-Besse B 3.0-1 Revision O

lnformation Only LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. lt is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, t hour is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electricaIgrid.Thetimelimitsspecifiedto@tlowerMoDESof operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, "Completion Times."

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met;

b. The LCO is no lpnqer applicable.

bq A Condition exists for which the Required Actions have now been performed; or Gd. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. lf the unit is in a lower MODE of operation when a shutdown is required, the time Iimit for

@thenextlowerMoDEappIies.IfalowerMoDEis

@inlesstimethanallowed,however,thetotaIaIIowable timetor@IMoDE5,orotherapplicableMoDE,isnotreduced.

Forexample,ifMoDE3is@in2hours,thenthetime Davis-Besse B 3.0-3 Revision O

lnformation Only LCO Applicability B 3.0 allowedfor@MoDE4isthenext11hours,becauSethe total timefor@

Davis-Besse B 3.0-3 Revision O

lnformation Only LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)

MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reaehfltg1 a Iower MODE of operation in less than the total time allowed.

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

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Spent Fuel Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. lf the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1 , 2,3, or 4, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 to "Suspend movement of irradiated fuel assemblies in spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

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

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

Davis-Besse B 3.0-4 Revision O

LCO Applicability lnformation Only B 3.0 nd the Required Actions followed after entrv into the Applicability.

Davis-Besse B 3.0-4 Revision O

lnformation Only LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

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

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

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "lndustry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the Davis-Besse B 3.0-5 Revision g

LCO Applicability lnformation Only B 3.0 requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability, LCO 3.0.4.b may be used with single or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

Davis-Besse B 3.0-5 Revision O

Information Only LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

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

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

), and may be applied to other Specifications based on NRC plant specific approval.

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

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

Davis-Besse B 3.0-6 Revision O

LCO Applicability lnformation Only B 3.0 BASES LCO 3.0.4 (continued)

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

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been pefformed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within Iimits) and restoring compliance with the affected LCO.

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

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preve ntive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other pracllgable alternatives that complv with Required Actions and that do not reouire ch ino the MODE or other snecified conditions in the Applicability, in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not ntended to be used reneatedlv An example of demonstratinq equip is OPERABLE with the Reouired Actions not met is opening a manual valve that was- qlosed to complv with Required Actions to isolatg q.-flqwpath with excessive Reactor Coolant Svstem (RCS) Pressure Isolation Va Ive (PlV) leakaoe in order to nerform testing to dernonstrate tXat. RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPEBAEILITY include instances in which it is necessarv to Lq,t<9, an inoperable channel or trip svstem out of a tripned condition that was di bv a Reouired Action. if there is no Required Action Note fqr: this purpose. An example of verifvinq OPERABILITY of equipment removed fror.n service is takinq a tripped Davis-Besse B 3.0-7 Revision g

LCO Applicability lnformation Only B 3.0 channel out of the tripped c,ondition to permit the logic to function and indicate the appropriate response during performance of required testinq on the inoperable channel.

ins

@ of demonstrating the OPERABILITY of other equipment isare taking an inoperable channel or trip system out of the tripped condition llto prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) ether equiprneffi{s taking an ineperable ehannel er triB system eut ef the

@opermitthelogictofunctionandindicatethe appropriate response during the performance of required testing on another channel in the same trip system.

The administrative controls in LCO .0.5 aoolv in all cases to svstems or components in Chapter 3 of the Tech nical Soecifications. as Iono as the testino could not be conducted ile comolvino with the Reouired Actions. This includes the realio nment or reoositionino of redundant or alternate equipment or trains previouslv manipulated to comply wilh ACTIONS, as well as equipment removed from service or declared inoperable to complv with ACTIONS.

Davis-Besse B 3.0-7 Revision g

lnformation Only SR Applicability B 3.0 BASES SR 3.0.2 (continued)

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surueillances for which the 25o/o extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial peformance of the Required Action, whether it is a pafticular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly me+ely o extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

sR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been @ within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

ThisdeIayperiodprovidesanadequatetimeto@

Surveillances that have been missed. This delay period permits the of a Surveillance before complying with Required Actions or other remedial measures that might preclude of the Surveillance.

Davis-Besse B 3.0-15 Revision O

lnformation Only SR Applicability B 3.0 BASES SR 3.0.3 (continued)

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situation$, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel Ioading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 3.0.3 is onlv applicable if there is a reasonable expectation the associated eouinment is OPE E or that variables are within limits.

and it is expected that the Surveill ance will be met when oerformed.

Manv factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and anv other indications, tests, or activities that miqht support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relav contact that was not tested as required in accordance with a pafticular SR. but previous su I oerformances of the SR included the relav contact; the adiacent, phvsicallv connected relav contacts were tested durinq the SR performance: the subiect relay contact has been tested bv another SR: or historical operation of the subieelrelay contaet has been successful. lt is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determininq whether there is a reasonable exnectation a Surveillance will be met when performed should increase based on the Ienqlh. g-f..ti,nte q!n_ce thg last performance of the Surveillance. lf the Surveillance has been pedormed recentlv. a review of the Surveillance historv and equipment performance mav be sufficient to support a reasonable expectation that the Surueillance will be met when pedormed.

For Surveillances that have not been performed for a lonq period or that have never been peformed, a riqorous evaluation based on obiective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail Davis-Besse B 3.0-16 Revision O

lnformation Only SR Applicability B 3.0 to allow a knowledqeable individual to understand the basis for the determination.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used @

to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may Davis-Besse B 3.0-16 Revision g

lnformation Only LCO Applicability B 3.0 B 3.0 LtMTING CONDTTlON FOR OPERATTON (LCO) APPLTCABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless o,thenryise specified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified Iimits. lf this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the (continued)

PERRY - UNIT 1 B 3.0-1 Revision No. 6

lnformation Only LGO Applicability B 3.0 BASES (continued)

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a An associated Required Action and Completion Time is not met and no other Condition applies; or

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the AGTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0"3 be entered immediately.

This Specification delineates the time Iimits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LGO and its ACTIONS. lt is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, t hour is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the Ioad dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to rea@IIEI lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE, This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

(continued)

PERRY - UNIT 1 B 3.0-3 Revision No. O I

lnformation Only LCO Applicability B 3.0 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met.

b. The LCO is no Ionoer aoolicable.

bg. A Condition exists for which the Required Actions have now been performed.

eel. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. lf the unit is in a lower MODE of operation when a shutdown is required, the time Iimit for reaeh+Hgenlegg the next lower MODE applies. If a lower MoDEis@inIesstimethanallowed,however,thetotal allowable time to reashentel MODE 4, or other applicable MODE, is not reduced.Forexample,ifMoDE2is@in2hours,thenthe time allowed for reaching MODE 3 is the next 1 t hours, because the total timefor@MoDE3isnotreducedfromtheaIIowab!elimit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to

@!qalowerMoDEofoperationinlessthanthetotaItimeaIlowed.

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

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, "Fuel Pool Water Level." LCO 3.7.7 has an Applicability of "During movement of irradiated fuel (continued)

PERRY - UNIT 1 B 3.0-4 Revision No. O I

lnformation Only LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the associated fuel storage pool." Therefore, this LCO can (continued) be applicable in any or all MODES. lf the LCO and the Required Actions of LCO 3.7 .7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in Iieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. lt allows placing the unit in a MODE or other specified condition stated in that Applicability (e.9., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered pen+i ollowinq entrv into the MODE or other specified condition in the Applicability will permit continued operation within the MOPE o_t other specified condition for an unlimited period of time. Compliance with that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable Ievel of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in and the Required Actions followed after entry into the Applicabilitv.

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

LCO 3.0.4.b allows entry into a MODE or other specifled condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the PERRY - UNIT 1 B 3.0-5 Revision No. 5 I

lnformation Only LCO Applicability B 3.0 results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

(continued)

PERRY - UNIT 1 B 3.0-5 Revision No. 5 I

Information Only LCO Applicability B 3.0 BASES LCO 3.0.5 The administrative controls ensure the time the equipment is returned to (continued) service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.

eg{+i isn other practicable alternatives that complv with Required Actions and that do not require chanqins the IVIODE or other specified conditions in the Applicabilitv in order to demonstrate equipment is OPERABLE LCO 3.0.5 is not intended to be used repeatedlv.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is openinq a manual valve that was closed to complv with Required Actions to isolate a flowpath with excessive Reactor Coolant Svstem (RCS) Pressure lsolation Valve (PlV) leakaqe in order to perform testins to demonstrate that RCS PIV Ieakase is now within limit Examples of demonstratinq equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip svstem out of a tripped condition that was directed bv a Required Action. if there is no Required Action Note for this purpose. An example of verifving OPERABILITY of equipment removed from service is takinq a tripped channel out of the tripped condition to permit the loqic to function and indicate the appropriate response during performance of required te.stino on the inoperable channel. An+xampbExamples of demonstrating the OPERABILITY of other equipment irsare taking an inoperable channel or trip system out of the tripped condition llto prevent the trip function from occurring during the performance of an SR on another channel in the other trip system-., or 2)

OPERABItITY ef ,ether eguipment is taking an ineperable ehannel er trip o permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

The administrative controls in LCO 3.0.5 applv in all cases to svstems or components in Chapter 3 of the Technical Specifications, as Ionq as the testinq could not be conducted while complving with the Required Actions. This includes the realionment or repositioninq of redundant or alternate equipment or trains previously manipulated to complv with ACTIONS. as well as equipment removed from service or declared inoperable to complv with ACTIONS.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported PERRY - UNIT 1 B 3.0-7 Revision No. O

lnformation Only LCO Applicability B 3.0 system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

\Mren a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported (continued)

PERRY - UNIT 1 B 3.0-7 Revision No. O I

lnformation Only SR Applicability B 3.0 BASES sR 3.0.2 The 25% extension does not significantly degrade the reliability that (continued) results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25o/o extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example is in the Primary Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly mer+ly o extend Surueillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

sR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been @ within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified (continued)

PERRY - UNIT 1 B 3.0-12 Revision No. 4

lnformation Only SR Applicability B 3.0 BASES sR 3.0.3 Frequency, whichever is greater, applies from the point in time that it is (continued) discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.Thisdelayperiodprovidesadequatetimeto@

Surveillances that have been inadvertently missed. This delay period permits the of a Surveillance before complying with Required Actions or other remedial measures that might preclude of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surueillance being performed is the verification of conformance with the requirements.

ffien a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.9., priorto entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 also provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 3.0.3 is onlv applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.

Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed. and altv other indications, tests, or activities that misht support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relav contact that was not tested as required in accordance with a particular SR. but previous successful performances of the SR included the relay contact, the adjacent, physically connected relav contacts were tested durinq the SR performance: the subiect relav contact has been tested bv another SR, or historical operation of the subject relav contact has been successful. lt is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determininq whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the PERRY - UNIT 1 B 3.0-13 Revision No, 4 I

lnformation Only SR Applicability B 3.0 lenqth of time since the last performance of the Surveillance. lf the Surveillance has been performed recentlv. a review of the Surveillance historv and equipment performance mav be sufficient to support a reasonable expectation that the Surveillance will be met when performed.

For Surveillances that have-npt beqn, p.g{prmed for a lonq period or that have never been performed. a rigorous evaluation based on objective evidence should provide a. h,igh degre--e-of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledqeable individ al to understand the basis for the determination.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used @

o extend (continued)

PERRY - UNIT 1 B 3.0-13 Revision No. 4 I

v t e Letter Sequence Request
CAC:MG0133, (Approved, Closed) CAC:MG0136, (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2017-08-11 [Table View]

L-17-108, Application to Revise Technical Specifications to Adopt TSTF -529. Clarify Use and Application Rules

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L-17-108, Application to Revise Technical Specifications to Adopt TSTF -529. Clarify Use and Application Rules

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SUBJECT:

Enclosures:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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