L-2017-116, Response to Request for Additional Information Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.5

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Response to Request for Additional Information Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.5
ML17184A176
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 07/03/2017
From: Deboer D
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9119, CAC MF9120, L-2017-116
Download: ML17184A176 (27)
v • d • e


Text

  • I=PL.

JUL 0 3 2017 .

L-2017-116 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001

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Docket Nos. 50-335 and 50-389 Renewed Facility Operating Licenses DPR-67 and NPF-16 Response to Request for Additional Information Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add NewTS 3.0.5

References:

1. Florida Power & Light Company letter L-2017 -002, License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instmmentation and Add NewTS 3.0.5, January 23, 2017 (ADAMS Accession No. ML17025A399)
2. NRR E -Mail Capture, Request for Additional Information, St Lucie Nuclear Plant, Units 1 And 2, Docket Nos. 50-335 and 50-389, License Amendment Request to Revise Limiting Conditions for Operation 3.0.2 and Add 3.0.5 CACS MF9119 & MF9120, June 1, 2017 In Reference 1, Florida Power & Light Company (FPL) submitted license amendment requests to modify the St. Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications (TS) by limiting the MODE of applicability for the Reactor Protection System (RPS), Startup and Operating Rate of Change of Power - High, functional unit trip. The proposed license amendments additionally added new Limiting Conditions for Operation (LCO) 3.0.5 and relatedly modified LCO 3.0.2, to provide for placing inoperable equipment under administrative control for the purpose of conducting testing required to demonstrate operability.

In Reference 2, the NRC determined that additional information is required to complete its review.

The enclosure to this letter provides FPL's response to the request for additional information (RAI) .

In addition, as discussed in the enclosure, FPL is proposing additional changes to the St. Lucie Unit 1 and St. Lucie Unit 2 TS pages that were included in Reference 1.

Attachment 1 to this enclosure provides the existing St. Lucie Unit 1 TS pages marked up to show the proposed changes. Attachment 2 to this enclosure provides the existing St. Lucie Unit 2 TS pages marked up to show the proposed changes. Attachment 3 provides the St. Lucie Unit 1 TS pages retyped (clean copy) with revision bars to identify the proposed changes. Attachment 4 provides the St. Lucie Unit 2 TS pages retyped (clean copy) with revision bars to identify the proposed changes. Attachment 5 provides the existing St. Lucie Unit 1 TS Bases pages marked up

St. Lucoie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Page 2 of2 to show the proposed changes. Attachment 6 provides the St. Lucie Unit 2 TS Bases marked up pages. The TS marked up pages, retyped (clean copy) TS pages and TS Bases marked up pages supersede the corresponding pages provided in Reference 1. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendments.

The supplements included in this response provide additional information that clarifies the

_ _ __...application do not expand the sco e of the apj2lication as origigallx noticed and should not chang.e.:. . _ _ _ _ _ __

the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register.

This letter contains no new or revised regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Mike Snyder, St. Lucie Licensing Manager, at (772) 467-7036.

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

Executed on JUL 0 3 2017 Sincerely, Dan DeBoer Site Director Florida Power & Light Company

Enclosure:

FPL Response to Request for Additional Information cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 Ms. Cindy Becker, Florida Department of Health

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 1 of 25 Enclosure FPL response to NRC Request for Additional Information (RAI) dated June 1, 2017 Regarding License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.5.

.. - Proposed Unit 1 Technical Specifications Pages (markup) - Proposed Unit 2 Technical Specifications Pages (markup) - Proposed Unit 1 Technical Specifications Pages (clean copy) - Proposed' Unit 2 Technical Specifications Pages (clean copy) - Proposed Unit 1 Technical Specifications Bases Pages (markup) - Proposed' Unit 2 Technical Specifications Bases Pages (markup)

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 2 of 25 Enclosure In an email memorandum dated June 1, 2017, the Technical Specifications Branch (STSB) of the NRC Office of Nuclear Reactor Regulation requested in RAI-MF9119/MF9120-STSB-01, additional information regarding FPLs License Amendment Request (LAR) dated January 23, 2017 for St. Lucie Unit 1 and St.

Lucie Unit 2. FPLs response follows:

RAI-MF9119/MF9120-STSB-01 By letter dated January 23, 2017, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17025A399), Florida Power & Light (FPL), submitted a license amendment request (LAR) for St. Lucie Units 1 and 2. The LAR proposes to modify the Unit 1 and Unit 2 Technical Specifications by limiting the MODE of applicability for the Reactor Protection System, Startup and Operating Rate of Change of Power - High, functional unit trip. Additionally, the proposed license amendments add new Limiting Conditions of Operation (LCO) 3.0.5 and relatedly modifies LCO 3.0.2, to provide for placing inoperable equipment under administrative control for the purpose of conducting testing required to demonstrate OPERABILITY. The staff has identified areas where additional information is needed to complete the review.

The licensees proposed new TS 3.0.5 states the following:

Equipment removed from service or declared inoperable to comply with ACTION(s) 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.

The licensees proposed revised TS LCO 3.0.2 states:

Upon discovery of a failure to meet an LCO, the Required ACTION(s) of the associated conditions shall be met, except as provided in LCO 3.0.5. lf the LCO is met or is no longer applicable prior to expiration of the specified time interval(s), completion of the Required ACTION(s) is not required, unless otherwise stated.

The current Units 1 & 2 TS LCO 3.0.1 states:

Compliance with the Limiting Conditions for Operations (LCO) contained in the succeeding specifications is required during OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

The proposed new TS LCO 3.0.5 is an exception to proposed revised LCO 3.0.2 as clearly addressed in the licensees license amendment request. However, the proposed new TS LCO 3.0.5 is also an exception to the second premise of the current LCO 3.0.1 which states: ..except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

Please provide the following:

1. A revised TS LCO 3.0.1 reflecting new LCO 3.0.5 as an exception to its second premise.
2. A revised new TS LCO 3.0.5 reflecting the second premise as an exception to LCO 3.0.1.

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 3 of 25 FPL Response As the NRC notes in RAI-MF9119/MF9120-STSB-01 above, the second premise of TS LCO 3.0.1 states that the associated ACTION requirements shall be met upon failure to meet the Limiting Conditions for Operation (LCO). As such, FPL acknowledges that modifying TS LCO 3.0.1 to specify that the proposed TS LCO 3.0.5 is an exception to TS LCO 3.0.1 is appropriate.

However, FPL notes that the second premise of TS LCO 3.0.1 is redundant with the proposed change to TS LCO 3.0.2 specified in Reference 1 (below), which states that upon discovery of a failure to meet an LCO, the required ACTION(s) of the associated conditions shall be met except as provided in TS LCO 3.0.5. Hence, modifying TS LCO 3.0.1 similarly would further complicate TS LCO 3.0.1 with requirements and exceptions that are repeated in TS LCO 3.0.2.

FPL proposes instead to replace TS LCO 3.0.1 with the analogous LCO 3.0.1 provided in NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants (Reference 2). Replacing TS LCO 3.0.1 with the LCO 3.0.1 provided in NUREG 1432 removes the redundancy with TS LCO 3.0.2 and thereby removes the need for TS LCO 3.0.1 to specify the proposed TS LCO 3.0.5 exception. The proposed change to TS LCO 3.0.1 will apply to the St.

Lucie Unit 1 and the St. Lucie Unit 2 TS. However, unlike the LCO 3.0.1 provided in NUREG 1432, the proposed change to TS LCO 3.0.1 will not specify exceptions to NUREG 1432 LCO(s) 3.0.7, 3.0.8, and 3.0.9 since the St. Lucie Unit 1 and Unit 2 TS do not contain these LCO(s).

Attachment 1 to this enclosure provides the existing St. Lucie Unit 1 TS pages marked up to show the proposed changes. Attachment 2 to this enclosure provides the existing St. Lucie Unit 2 TS pages marked up to show the proposed changes. Attachment 3 provides the St. Lucie Unit 1 TS pages retyped (clean copy) with revision bars to identify the proposed changes. Attachment 4 provides the St. Lucie Unit 2 TS pages retyped (clean copy) with revision bars to identify the proposed changes. Attachment 5 provides the existing St. Lucie Unit 1 TS Bases pages marked up to show the proposed changes. Attachment 6 provides the St. Lucie Unit 2 TS Bases marked up pages. The TS marked up pages, retyped (clean copy) TS pages and TS Bases marked up pages supersede the corresponding pages provided in Reference 1. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendments.

References:

1. Florida Power & Light Company letter L-2017-002, License Amendment Request to Revise the Technical Specifications (TS) for the Reactor Protection System (RPS) Power Rate-of-Change Instrumentation and Add New TS 3.0.5, January 23, 2017 (ADAMS Accession No. ML17025A399)
2. NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Volume 1, Specifications, Revision 4.0 (Accession No. ML12102A165)

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 4 of 25 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGES (MARKUP)

(2 pages follow)

St. Lucie_Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 5 of 25 Attachment 1 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEIL LANCE REQUIREMENTS 3/4.0 APPLICABILITY INSERT LCO 3.0.1 (see next page)

LIMITING CONDITION FOR OPERATION 3.0.1 Geffi(91ianoe witi1 ti1e Lifl'!iliR!iJ GenelitieRs for O~eFatien (bGOj eentainee in

~~~~~~~~~~A~e~s~H~e~s~e~eel~i~n~g~s~p~es~i~fie~a~ti~e~n:s~is:r~e~q~~~ire~el~ T~IO~~~IA~,b~~~~O~D~E~a~e~r~e~th~e~r____j e~~r~in~g~t~l:i~e~O~P~E=R=*~~~

INSERT LCO 3.0.2 eeReitieRs sj9eeifiee ti1ereiR; e!<sept ti1at Hpen faiiHre to meet tl:le bimitin§ (see next page) Coiidiliolls fo1 Opel atio11, tl 1e associated ACTION 1eq1:1i1 en 1ents sin,: II be n1et.

t~OIICOII I 3.0 .2 1plie:1ICe ovith !l: speeifieatien 3Rall OJ!ist WAOR tAO FOEfHiFOffiOnts of ti'le Lifl'litiR§ GeRElitien fer Operation (LGOj and assoeiatoe ACTION re~;fwirerniHlt:>

....:)~ are net met within the s~esifieel tirne intep,*als. If tl:ie birniting Cenditien for Operation is restored prior to e>cpiration of tho speoifiod time intor.*als ,

eeffi(91etieR ef t11e AGTiml FOEfHireffients is net reetHired .

3.0.3 When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requirements , within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which specification does riot apply by placing it, as applicable in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> .

Where corrective measures are completed that permit operation under the ACTION requirements , the ACTION may be taken in accordance with the specified time limits as measured .from the time of failure to meet the LCO. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

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

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

INSERT LCO 3.0.5 (see next page) 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.

ST, LUCIE- UNIT 1 3/4 0-1 Amendment No. 4Q, W , '~-Gil,~

-St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 6 of 25 Attachment 1

'INS ERT I Limiting Conditio ns of Ope ration (LCO) shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

'INS ERT I 3.0.2 t Upon discovery of a failure to meet an L CO , the Required ACTION(s) of the associated conditions shall be met, except as provided in LCO 3.0.5. If the LCO is met or is no longer applicable prior to expiration of the specified time intervals, completion of the Required ACTION(s) is not required, unless otherwise stated .

IINS ERT I

~

3.0.5 Equipment removed from service or declared inoperable to comply with ACTION(s) may be returned to service under administrative control solely to perform testing required to demonstrate its OP ERABIUTY 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.

St. Loucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 7 of 25 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGES (MARKUP)

(2 pages follow)

-St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 8 of 25 Attachment 2 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0 .1 Col iipliallee 01 itl 1tlie Linliti11g Coiiditiolis for Operatle1 1eeRtaifle61fil'l'ie s~eeeeEitA§ speeifieatiens is requires suriR!'J the OPERATimJAL MODES or otbier senaitiens r:-I:-:N-:::S-:::E:-::R:-::T::-:-LC=o:-:3;::-.-:::0-;.2::-~speeifies ti'ierein; except ti'iat t:tpeR failure .te R'!eet the LiR'litiA!'J CeRsitieAs fer O~eratien ,

(see next page) ti'ie associates ACTION requireR'!ents shall be .11et.

3.0.2 ~~oReen,pliaRee with a speeifieatieA shall elEist wheA tbio FOEfblirornonts eftbie birnitiR9 Colidilioii fu1 Ope1atio11 and/o1 associated ;A.;GTIO~J requiren,eRts fire Ret R'!et withifl the SJ$esifiea tirne inter;cals. If tbie Lirnitin9 CeAelitieA fer O~eratieR is resterea ~rier te el<~iratieR ef the s~esifieel tiFRe iRtervals, seR'!~IetieA ef the ACTIO~! FOEjl:lireFReAts is Aet requires.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in tho associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

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. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in tho 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 o.ther specified condition in tho Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are staled in tho individual Specifications); or INSERT L CO 3.0. 5 c. When an allowance is stated in the individual value, parameter, or other Specification.

(see next page)

L----.------~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 tho unit.

ST. LUCIE- UN iT 2 3/4 0-1 Amendment No. <la eerreolea ,

'1-te-

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 9_of 25 Attachment 2

!INSERT I Limiting Conditions of Ope ration (LCO) shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

'INSERT I 3.0.2 t Upon discovery of a failure to meet an LCO, the Required ACTION(s) of the associated conditions shall be met, except as provided in LCO 3.0.5. If the LCO is .met or is no longer applicable prior to expiration of the specified time intervals, completion of the Req uired ACTION(s) is not required ,

unless otherwise stated .

IINSERT I

~

3.0.5 Equipment removed from service o.r declared inoperable to comply with ACTION(s) 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 exceptio.n to LCO 3.0.2 for the system returned to service under administrative contro l to perform the testing required to demonstrate OPERABILITY.

St. Lucie-Nuclear: Plant L-2017-116 Docket Nos. 50-335 and 50-389 EnClosure Page 10 of 25 Attachment 3 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGES (Clean Copy)

(1 page follows)

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 11 of 25 Attachment 3 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY biMI-T-ING--CONDI+/-ION J;OR OI?_ERAIJON 3.0.1 Limiting Conditions for Operation (LCO) shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

3.0.2 Upon discovery of a failure to meet an LCO, the Required ACTION(s) of the associated conditions shall be met, except as provided in LCO 3.0.5. If the LCO is met or is no longer applicable prior to expiration of the specified time interval(s), completion of the Required ACTION(s) is not required, unless otherwise stated .

3.0.3 When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable in :

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. Atleast COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> .

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the LCO . Exceptions to these requirements are stated in the individual specifications .

This specification is not applicable in MODES 5 or 6.

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. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in fhe 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
c. When 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.

3.0.5 Equipment removed from service or declared inoperable to comply with ACTION(s) 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.

ST. LUCIE - UNIT 1 3/4 0-1 Amendment No. 4Q, QS, ~. ~

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 12 of 25 Attachment 4 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGES (Clean Copy)

( 1 page follows)

St. Lucie Nuclear Plant L-2017-116 Docket -Nos. 50-335 and 50-389 Enclosure Page 13 of 25 Attachment 4 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation (LCO) shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

3.0.2 Upon discovery of a failure to meet an LCO, the Required ACTION(s) of the associated conditions shall be met, except-as provided in LCO 3.0.5. If the LCO is met or is no longer applicable prior to expiration of the specified time interval(s), completion of the Required ACTION(s) is not required, unless otherwise stated.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation . Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

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. When 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
c. When 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.

3.0.5 Equipment removed from service or declared inoperable to comply with ACTION(s) 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.

ST. LUCIE- UNIT 2 3/4 0-1 Amendment No. aa sorreste9 ,

4-7()

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 14 of 25 Attachment 5 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIO NS BASES PAGES (Markup)

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 15 of 25 Attachment 5

.,S:TIJ II ID .: TITLE : TE CHNI CAL SPECI FICATI m~ S 3.0 & 4.0 BASE SATIA CHMENT 2 OF ADM -25.04 P. E\IISO N NO .: UMITING CONDITIONS FOR OPERA.TIOt\1 AND SUR*!EI LLAN CE REQUIREMENTS ST. LUCIE UNIT 1

- - - - - - - - - -I _ _ _ _ _ _ _ _ _ ___.:Tc.:....A..:..:: =-

B:...=LE OF CONTEt\ITS SE CTIOt\1 BA.SES FOR SE CTIONS 3.0 & 4.0 .. .. ......... .... .............. ..... .... .......... .. .... ... ....... .............. .3 314.0 .A.PPLIC.A.BILITY ........ .. ........... .. ................. ............. .......... ..................... 3 HA SES ......................................................... ..... .. ...... .. .... ...... ...............3

3. 0.1 ................... .. ............... ..... ................ .......... ... ... ........ .................... 3 3.0 .2 .......... .... .. .. ...... ........:.. ...... .. .. ................. ********* * ................... .. .... .4
3. 0. 3 ........ .. ...... .. ............. .... ..... .... .. ........... ......................... ............... 5 3.0 .4 ** *** ** ** * ****** *** ** * *** **** ** ** ** *** ***** *** ***.** ***** ************* ** *** ******* ** **** **** *** ** **** 7

,.A.dd 3.0.5 I )

4.0.1 .......... ... .. .... ............. ....... ......... ...... .......... .......... ..... ................ 11

  • 4.0.2 .. .. ...... ...................... .. .... .. ... ................. ................... ........ .. ...... 13 4.0. 3 ............. .................................................................................. 13 4.0.4 ................................... ...................... ......................... ........... .. 15 4.0.5 ............... .......................................... ... ..... .............. ...... ... .... ... 16

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 16 of 25 Attachment 5 PAGE: ' ,,

SECTION NO .: TITLE: TECHNICAL SPECIFICATIONS 3.0 &4.0 BASES ATIACHMENT 2 OF ADM-25.04 REVISION NO.: LIMITING CONDITIONS FOR OPERATION 3 of 16

.AND SURVEILLANCE REQUIREMENTS

/ ST. LUCIE UNIT 1

_ _E3ASES FOR SECTIONS 3.0 & 4.0

. \ ...

3/4.0 APPLICABILITY BASES 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 of other specified condition of the Applicability statement for each Specification).

The specifications of this section establish tbe general requirements applicable to Limiting Conditions fo Operation. 'These requirements are based on the requirements for Limiti~~ Conditions for Operation stated in the Code of Federal Regulations, 10 ~FR 50.36(c)(2):

"Limiting conditions foro Jeration are the lowest functional capability or performance levels of eq uipment required for safe operation of the facility.

When a limiting conditior for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technica l specificatio unti l the condition can be met."

'I 3.0.1 'FIIi~ speeifleatiofl esteblisi'les !i=le Ap151ieability stateffieAt witi'liA eaet:l iAE:li¥iEhoal speeifiea!ieR as !i=le Feett~iFeffieR! ffif 'Hi=leR (i.e. , iR *wl9ieA 9FlERA=l=IEm,oll:

1\116BES or otl1er speeifieel eeflelitiofls~ eoflfefffiBflee fe fi'le l:iffiififl!;l 6eRaitieAs for 6peratior1 i~ rec:Jtlired for safe o~eFetiofl oftl'le feeilitr . =fi'le A6=fl8~~

reejl:liremeAts estaelisA ti'lese remeaial measl::IFes tt:lat FAl:IS~ ee tal~eA witl=liA specified tiffie liffiits wi'leA ti'le rOE!l:lireFAeAls ef a LiffiitiAg 6eAaitioR ffif 8peFBfttJR BFe Ret ffiet.

7 here are two basic types of ACTION requirements. The first specifies the remedial measures that perm" continued operation of the facility which is not further restricted by the time limits of the ACTION requirements . In this case ,

Add first

  • conformance to the ACTION requirements provides an acceptable level of paragraph from safety for unlimited continued operation as long as the ACTION requirements old LCO 3.0.2 continue to be met. The second type of ACTION requirement specifies a time (below) limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified 'limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a MODE or cond ition in wh ich the specification no longer applies. It is not intended that the shutdown ACTION requirements .be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and-50-389 Enclosure Page 17 of 25 Attachment 5 ECTION NO. : PAGE:

TITLE TECHNICAL SPECIFICATIONS 3:0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO.: LIMITING CONDITIONS FOR OPERATION 4 AND SURVEILLANCE REQU IREMENTS ST. LUCIE UNIT 1 3/4.0 APPLICABILITY (continued)

BASES (continued) 3.0.1 (continued)

The specified time limits of the ACTION reqt~irements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met.

The time limits of the ACTION requirements are also applicable when a system or component is removed from service forsurveillance testing or ACTION investigation of operational problems. Individual-specifications may include a cified time limit for the completion of a Surveillance Requirement when equip tis removed from service. In this case, the allowable outage time Reclocate limits of th requirements are applicable when this limit expires if the paragraph t o surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in become 1st which a new specification becomes applicable. In this case, the time limits of paragraph of new the ACTION requirements would apply from the point in time that the new LCO 3.0.2 ab ve specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.

This specification establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met an the associated ACTION requirE!ments have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) implementation of the ACTION requirements within the specified time interva l constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when Add as last compliance with a Limiting Condition for Operation is restored within the time interval specified in the associated ACTION requirements.

paragraph of LCO 3.0.2 LCO 3.0.5 provides for an exception to LCO 3.0.2 fo r the limited purpose of performing required testing to demonstrate either the OPERABILITY of equipment being returned to service or the OPERABILITY of other equipment.

Refer to the LCO 3.0.5 discussion for use.

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-3.89 Enclosure Rage 18 of 25 Attachment 5

>ECTDN PD.: TITLE: TECHNICAL SPECI FlU\ Tl ONS 3.0 & 4.0 B.A.SES ATI ACHMENT 2 0 F ADM-25. 04 REVISDN NO .: UMITING CONDITIOI\IS FOR OPERATION

.A.t>ID SURI/EI LL.A.t'JCE REQUIREMENTS

.-k""

ST. LUCIE UNIT 1 14.0 APPLICABILITY (continued)' -- -

BASES (continued)

.0.4 (continued)

Upon entry into a MODE or other specified condition in the Applicability vvit~1 t~1e 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 resot1red, until the LCO is met, or until the unit is not vl'ithin the .A.pplicability of the Technical Specification .

Surveillances do not have to be performed to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 4:0.4 Therefore, utilizing LCO 3.0.4 is not a violation ofSR 4.0 .1 or SR 4.0.4 .for any Surveillances that have not been performed on inoperable

  • equiprnent. Hcrwever, SRs must be met to ensure OPERABILITY prior to declaring t~1e associated equipment 0 PERABLE (or variable vi~thin limits) and restoring compliance with t~1e affected LCO.
13. 0. 5 (.A.dd lt*JSERT Jrorn next page) 1

St~ Lucie Nuclear Plant l-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 19 of 25 Attachment 5 INSERT 3.0.5 LCO 3.0.5 establishes t he allowance for restoring equipment to se rvice 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 p.r.o.Y.Lcte~xce p:tion to LCO 3.0.2 (fL9. to not comQ)y with the aQplicable Required Action(s)) to allow the performance of required testing to demonstrate either:

1. The OPERABILITY of the equipment being returned to service or,
2. 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 ndt provide time to perform any other preventive or corrective maintenance .

LCO 3.0 .5 speCifically states that equipment removed from service or declared inoperable to comply with ACTION(s) may be returned to service under administrative control solely to perform testing required to demonstrate the OPERABILITY of the equipment or that of other equipment. LCO 3.0.5 is limited to plant conditions where simultaneous testing and compliance with the required ACTION (s) is not possible. Hence LCO 3 .0 .5 may only be used if it is the only alternative to performing the required testing , regardless of whether the other alternatives present higher risk to the plant.

An example of demonstrating the OPERABILITY of equipment being returned to service is reopening a containment isolation valve that has been closed to comply with required ACTION{s) and must be reopened to perform the required testing .

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response dUring the performance of required testing on another channel in the same trip system.

References:

1. NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4, Volume 2, Bases (ML12102A169)
2. Enclosure 1 0: Case Study 6: ANO 1 Use of LCO 3.0.5 Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF (ML090640444)

St. LuG:ie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 20 -of 25 Attachment 6 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (Markup)

St. Lucie Muclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 21 of 25 Attachment 6 PAGE: .

SECTION NO .: TITLE TECHNICAL SPECIFICATIONS 3 :0 & 4.0 BASES ATTACHMENT 2 OF ADM-25 .04 REVISION NO.: LIMITING CONDITIONS FOR OPERATION of 1 AND SURVEILLANCE REQUIREMENTS ST. LUCIE UNIT.2 TABLE OF CONTENTS ---------

SECTION BASES FOR SECTIONS 3.0 & 4.0 ................. .... ... ..... ...... ...... ....... ....... .... ....... ... .. .. .... .. ... 3 3/4.0 APPLICABILITY .. ... ...... ... ..... ... ... ............. .. ...... ... .... .. .... ..... .. ..... .... .........3 BASES .. ....... ... .. .... .... .... ............... ... ... .. .. ... ... ... ..... .... ..... .. ...... .... ... ....... .3 3.0.1 ** ***** *'** *** *** *** **** ******* ***** *** *** *' *** **' *** ** *** *** ********* **** ************* *** **** ***3 3.0.2 ........ ....... ....... ................... ........ .... .......... ....... .... ... .... .......... .. ..... .4 3.0.3 ******* ***** *** **** *********** ** ** ** ******** **** ***** ****** **** ************ ******** **** **** ****-:5

~ ....._3 .0.4 ..... ...... ... .. .... ... ...... ....... ..... ....... ..... ..... ....... ..... ..... ........ .. .... ... .. ... .?

~

4.0.1 ..... ....... ............ .. ....... ... .......... .. .......... .... ..... ... ... .... ....... ............ 11 4.0.2 ....... ..... ... .. .... .. ....... .. ... .... .. ........... .... .. .... ... ..... ;.... .. ..... ..... ........ 13 4.0.3 ... .......... ..... .... ... .. .. .... .... ... .. .. ...... .. ......... ..... .... .............. ... .........1*3 4.0.4 ........ .. ... .. .. ....... ...... ... ...... ...... ...... ... .. .... ........ ... ..... .. ... .... .. .... ..... .15 4.0.5 .... .... ..... .. .... .............. ... ... .... ... .. ...... ... ... .. .. ... .... ... .... ... ...... ..... .. ..16

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 22 of 25 Attachment 6 (5 pages follow) jPAGE:

SECTION NO .: TITLE: TECHNICAL SPECIFICATION S

/(

3.0 & 4.0 BASES AITACHMENT 2 OFADM-25.04 REVISION NO.: LIMITING CONDITIONS FOR OPERATION of 1 AND SURVEILLANCE REQUIREMENTS K ST. LUCIE UNIT2  ;

BASES FOR SECTIONS 3.0 & 4.0 1 .,

3/4.0 APPLICABILITY BASES 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 of other specified condition of the Applicability statement for each Specification).

The specificatiom of this section establish the general requirements applicable to Limi ing Conditions for Operation. These requirements are based on the reqL irements for Limiting Conditions for Operation stated in the Code of Federai*F egulations, 10 CFR 50.36(c)(2):

"Limiting conditio r s for operation are the lowest functional capability or performance leve lp of equipment required for safe operation of the facility.

\Mien a limiting c< ndition for operation of a nuclear reactor is not met, the licensee shall shu down the reactor or follow any remedial action permitted by the technical s ecificatio n until the condition can be met."

\II 3.0.1 'fllis speeifieetiol'l es!eelisl'les !l'le AJ:!J:llieaaili~~* sl:a~eR'leAt ~.~itl=liA easl=l iAc;lividbl<~l S!=leeifieetiel'l es !l'le FeejttiFeffiel'll feF '*'f'ReA fi.e ., iA '*YRieA 9PE:Rflr=!=l9~dAb M88ES eF eU'leF s~eeified eeAelilieAs) eeAfeFffiEIAee le !Fie biffiiliA§ b9AEiilieAs fo1 epe1 etiou is FeejttiFed feF sere eJ:leFalieA ef !Fie faeilit-y. =!=l:le fl,G+IG~I FEI'lWiFeR'leAts estaelisl=l tl=lese FeR'leeial R'leaswFes tl=lat R'lwst ee tal~eA witl=liA speeifleEI tiA'Ie liR'lits wl:leA tl:le FeEjttiFeA'IeAts ef a UA'IiliA§ b9AditieA foF Add first "P"'"""" ""'here are two not basic types of ACTION requirements . The first specifies the m*t.

remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, paragraph from conformance to the ACTION requirements provides an acceptable level of old LCO 3.0 .2 safety for unlimited continued operation as long as the ACTION requi rements (below) continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the faci lity in a MODE or condition in which the specification no longer applies. It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

St. Lucie Nuclear ~!ant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 23 of 25 Attachment 6 PAGE: *

!SECTION NO. : TITLE TECHNICAL SPECIFICATIONS 3:0 & 4.0 BASES ATTACHMENT 2 OF ADMc25.04 REVISION NO.: LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS ST. LUCIE UNIT 2 /:... . *.:**.

3/4.0 APPL~ABILITY ~ontinued)

BASES (continued) 3.0.1 (continued)

The specified time limits ofthe ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met.

The time limits of the ACTION requirements are also applicable when a system or component is removed from sentice forsunteillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Sunteillance Requirement when Reclocate equipment is removed from sentice. In this case, the allowable outage time paragraph to limits of the ACTION requirements are applicable when this limit expires if the become 1 st sunteillance has not been completed. When a shutdown is required to h f comply with ACTION requirements, the plant may have entered a MODE in 0

paragrap bnew which a new specification becomes applicable.. In this case, the time limits of LCO 3.0.2 a ove the ACTION requirements would apply .from the point in time that the new

"~ specification becomes applicable if the requirements of the Limiting Condition I.. n ~ for Operation are not met.

Add as last

St. Lucie Nuclear Plant L-2017-116

-Docket Nos. 50-335 and 50-389 Enclosure Page 24 of 25 Attachment 6

>B:TIJ N ID .:
  • TITLE: TE CHNICAL SPECIFICATIONS 3.0 & 4..0 BASES.ATIA CHMENT 2 OF ADM- 25.04 RE<II S ON NO .: U M ITI NG CONDITI ONS FOR 0 PERA. Tlot'~

AND SURVEILLAN CE REQ Ul REM ENTS ST. LUCIE UNIT 2 14.0 APPLICABILITY (continued)

BASES (c ontinued)

.0.4 (continued)

Upon entry into a MODE or other specified condition in the .A.pplicability witr1ihe LCO not met, LCO 3. 0.1 and LCO 3.0.2 require entry into tr1e applicable Conditions and Required Actions until the Condition is re solved, until the LCO is met, or until the unit is not V1~thin tt*1e Applicability of tt*1e Tecl1nical Spe cification.

Surveillances do not 11ave to be .performed to be performed on the associated inoperable equipment (or on variable s outside the specified limits), as permitted bV SR 4.0.4 Therefore, utilizing LCO 3.0 .4 is not a violation ofSR 4.0.1 or SR 4.0.4 for any Surveillances tl1at have not been performed on inoperable equipment. However, SRsmustbe metto ensure OPER.A.BILITY prior to declaring the associated equipment 0 PERABLE (orvariable Vl~thin limits) and restoring compliance with tt1e affected LCO.

j3. 0. 5 (.A.dd INSERT fro m next page) 1

St. Lucie Nuclear Plant L-2017-116 Docket Nos. 50-335 and 50-389 Enclosure Page 25 of 25 Attachment 6 INSERT 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 ofthis Specification is to provide-an excepti.onlo-L.CO 3.02 (e.g _to..noJ cQmpJy wiibJhe applicable Required Action(s)) to allow the peliormance of required testing to demonstrate either:

1. The OPERABILITY of the equipment being returned to service or,
2. 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 preventive or corrective maintenance.

LCO 3.0.5 specifically states that equipment removed from service or declared inoperable to comply with ACTION(s) may be returned to service under administrative control solely to perform testing required to demonstrate the OPERABILITY of the equipment or that of other equipment. LCO 3.0.5 is limited to plant conditions where simultaneous testing and compliance with the required ACTION(s) is not possible. Hence LCO 3.0.5 may only be used if it is the only alternative to performing the required testing, regardless of whether the other alternatives present higher risk to the plant.

An example of demonstrating the OPERABILITY of equipment being returned to service is reopening a containment isolation valve that has been closed to comply with required ACTION(s) and must be reopened to perform the required testing.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out ofthe tripped condition to prevent the trip function from occurring during the performance of requ ired testing on another channel in the other trip system A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the perfo rmance ofr'equired testing on another channel in the same trip system.

References:

1. NUREG 1432, Standard Technical Specifications- Combustion Engineering Plants, Revision 4, Volume 2, Bases (M L12102A 169)
2. Enclosure 1O; Case Study 6: ANO 1 Use of LCO 3.0.5 Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF (ML090640444)
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