LIC-04-0047, License Amendment Request, Application for Technical Specification Improvement to Implement a Risk Informed Alternative to the Existing Restoration Period for the High Pressure Safety Injection System

License Amendment Request, Application for Technical Specification Improvement to Implement a Risk Informed Alternative to the Existing Restoration Period for the High Pressure Safety Injection System

ML041410041
Person / Time
Site:	Fort Calhoun
Issue date:	05/14/2004
From:	Ridenoure R Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-04-0047
Download: ML041410041 (29)

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Omaha PublicPowerDistnct 444 South 16th Street Alall Omnala NE 68102-2247 May 14,2004 LIC-04-0047 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

Docket No. 50-285

SUBJECT:

Fort Calhoun Station Unit No. 1 License Amendment Request, "Application For Technical Specification Improvement to Implement a Risk-Informed Alternative to the Existing Restoration Period for the high Pressure Safety Injection System" Pursuant to 10 CFR 50.90, Omaha Public Power District (OPPD) hereby proposes to make changes to the Fort Calhoun Station (FCS) Technical Specifications (TS).

The proposed change provides a risk-informed alternative to the existing restoration period for the High Pressure Safety Injection (HPSI) System. The FCS application of the risk informed change integrates Westinghouse Owner's Group (WOG) recommendations identified in WCAP-15773, "Joint Application Report for the Implementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System." The application involves the following elements:

1. Extension of the current Completion Time (CT) of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for a single HPSI pump inoperable to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> "frontstop" for a HPSI train.

2. Include an action statement to be implemented when the "frontstop" time cannot be met that would allow this period to be extended based on acceptable results of a risk evaluation. The maximum allowable extension will be limited to 30 days ("backstop")

even for risk insignificant extensions.

The overall net impact of this change is considered from very small to risk neutral as the risks of continued operation are offset by implementation of contingency actions, where necessary, and by avoidance of transition risks. The proposed change is based on WCAP-15773, "Joint Application Report for the Implementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System," conducted by the Westinghouse Electric Company, LLC (WEC) on behalf of the Combustion Engineering Owners Group (CEOG). The changes are consistent with Rev. 0 of Technical Specifications Task Force (TSTF) Traveler TSTF-424. The proposed required actions and risk evaluations will be performed consistent with the flexible CT implementation guidance in Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," May 2000, and Section 11 of Employment with Equal Opportunity ¢ D

U. S. Nuclear Regulatory Commission LIC-04-0047 Page 2 NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised, clean TS pages. Implementation of TSTF-424 also involves various changes to the TS Bases.

OPPD requests approval of the proposed amendment by January 15, 2005. OPPD requests 120 days to implement this amendment. No commitments are made to the NRC in this letter.

OPPD also requests the NRC Staff to consider FCS to become a pilot plant for the risk-informed Technical Specifications (RITS) for "Flexible Allowable Outage Times (AOT)", RITS Initiative 4b. In this effort we will work with the WOG and Nuclear Energy Institute (NEI) to assure that our efforts are compatible with the approaches already underway by the other Owners Groups.

We request that NRC reviews of our submittals, including any required reviews of our Probabilistic Risk Analysis (PRA) Model necessary to support our application, be granted a fee waiver pursuant to the provisions of 10 CFR 170.1 1, specifically:

1. The request is to assist in developing a NRC regulatory guide (to provide/endorse the risk management process) in accordance with 10 CFR 170.1 1(a)(1)(ii).

2. The request is to support NRC generic regulatory improvements (risk management technical specifications), in accordance with 10 CFR 170.11 (a)(1)(iii).

Please inform us of your decision on our request for fee waiver as soon as practical.

In accordance with 10 CFR 50.91, a copy of this application is being submitted to the designated Nebraska State Official.

I declare under penalty of perjury that the foregoing is true and correct. (Executed on May 14, 2004)

If you have any questions or require additional information, please contact Dr. R. L. Jaworski at (402) 533-6833.

Sincerely,

U. S. Nuclear Regulatory Commission LIC-04-0047 Page 3 RTR/TRB/trb Attachments:

1. Fort Calhoun Station's Evaluation

2. Markup of Technical Specification Pages

3. Proposed Technical Specifications (clean) c: B. S. Mallett, NRC Regional Administrator, Region IV A. B. Wang, NRC Project Manager J. G. Kramer, NRC Senior Resident Inspector Division Administrator - Public Health Assurance, State of Nebraska

LIC-04-0047 Page 1 ATTACHMENT 1 Fort Calhoun Station's Evaluation for Amendment of Operating License

2.0 DESCRIPTION

OF PROPOSED AMENDMENT

3.0 BACKGROUND

4.0 REGULATORY REQUIREMENTS & GUIDANCE

6.0 REGULATORY ANALYSIS

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

8.0 ENVIRONMENTAL CONSIDERATION

9.0 PRECEDENCE

10.0 REFERENCES

LIC-04-0047 Page 2 Fort Calhoun Station's Evaluation For Amendment of Operating License

1.0 INTRODUCTION

The proposed change provides a risk-informed alternative to the existing restoration period for the High Pressure Safety Injection (HPSI) System, allowing this period to be extended from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> up to 30 days. The overall net impact of this change is considered risk neutral as the risks of continued operation are offset by implementation of contingency actions, where necessary, and by avoidance of transition risks. The proposed change is based on WCAP-15773, "Joint Application Report for the Implementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System," (Reference 10.1) conducted by the Westinghouse Electric Company, LLC (WEC) on behalf of the Combustion Engineering Owners Group (CEOG).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT The proposed change to TS 2.3(2)b includes a risk-informed alternative to shutting down the plant after the expiration of a Completion Time (CT) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Provided a risk evaluation demonstrates the acceptability for continued operation given the current plant configuration, the CT may be extended for up to 30 days. Contingency actions or compensatory measures may be required to support the acceptable results of the risk assessment. The Bases associated with this TS are being revised to reflect the intent and proper use of the proposed alternative.

TS 2.3(2)b allows continued power operation with an inoperable Emergency Core Cooling System (ECCS) HPSI pump for a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Hence, if an ECCS train is inoperable due to preventative or corrective maintenance on a HPSI subsystem, the train must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If this train is not restored to an operable status within this period of time, other TS requirements would direct that the plant be placed, within a specified time period, in an operating mode where the TS does not apply.

This proposal requests the addition of a risk informed Condition to TS 2.3(2)b to provide actions to be taken when one HPSI subsystem is declared inoperable and the current CT (hereafter referred to as the "frontstop" CT) is not long enough to effect restoration of operability or to support preventative maintenance or modification. The CT beyond the frontstop will be controlled via risk management processes consistent with the Maintenance Rule of 10 CFR 50.65(a)(4). A maximum CT of 30 days (hereafter referred to as the "backstop" CT) will provide a limit to the time any TS HPSI component, regardless of risk, may remain inoperable. The frontstop and backstop CTs are the constituent parts of the flexible CT approach.

LIC-04-0047 Attachment I Page 3 In addition to the above, existing TS 2.3(2)e is modified to address cases where two or more subsystems are inoperable for reasons other than TS 2.3(2)a or TS 2.3(2)b, provided each ECCS train remains capable of supplying 100% of its assumed flow equivalent. In this event, the subsystems must be restored to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This change is necessary since there are several events that may render a HPSI subsystem inoperable, but do not prevent the HPSI subsystem from delivering its assumed flow to the core (i.e., the subsystem remains functional). Examples of such events may include loss of HPSI pump room cooling, degradation of HPSI pump mini-recirc capability, and loss of auto-start capability of a HPSI pump.

TS 2.3(1)f is being changed to require that one HPSI train be operable on each 4160V engineered safety feature bus, consistent with NUREG-1432. The current TS 2.3(2)e is also being deleted in its entirety consistent with the concept of a subsystem or train based TS. This change is consistent with NUREG-1432, with the exception of the change from "one or more trains" to "two or more subsystems" which is consistent with TSTF-424. Additionally, TS 2.3(1)j is being deleted for consistency with NUREG-1432, TSTF-424 and the changes to TS 2.3(2)e. TS 2.3(2)i is also being added consistent with NUREG-1432 and TSTF-424 to provide direction to enter TS 2.0.1 if less than 100% of the ECCS flow equivalent to a single operable train is available Also, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frontstop CT of 2.3(2)b is proposed to be extended to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, consistent with NUREG-1432 and TSTF-424. The 72-hour Completion Time is based on an NRC study (Reference 10.2) using a reliability evaluation assuming one non-functional HPSI subsystem and is a reasonable amount of time to effect most repairs. This allows some time to correct ECCS component inoperabilities. This allowance is acceptable because of the redundancy and diversity of ECCS and recognition of the fact that the inoperability of one component in a train does not necessarily render the ECCS incapable of performing its intended safety function.

The intent of these changes is to enhance overall plant safety by avoiding potential unscheduled plant shutdowns and the potential regulatory burden caused by the generation of Notice of Enforcement Discretions (NOED). The proposed change will integrate TS and Maintenance Rule processes to provide for increased flexibility in maintenance and surveillance scheduling.

3.0 BACKGROUND

In response to the NRC initiative to improve plant safety by assessing the risks associated with certain TS equipment related inoperabilities, the Combustion Engineering Owners Group (CEOG) in cooperation with the nuclear industry has undertaken a program for identifying features of the plant TSs that would benefit from a risk informed approach. This effort is part of an eight-tiered initiative established by the nuclear industry in 1999 (Reference 10.3), several limited scope risk informed TS (RITS) improvements have already been proposed by the industry. These include an improvement to the process of treating missed TS surveillances -

Technical Specification Task Force (TSTF) 358 (Reference 10.4), and elimination of selected mode restraints on less risk-significant components - TSTF 359 (Reference 10.5). This aspect of

LIC-04-0047 Page 4 the industry RITS effort has been identified in Reference 10.3 as Initiative 4B. This initiative focuses on the change to selected TSs that would allow continued "at power" plant operation under conditions when the component cannot be returned to service in the defined fixed CT (frontstop) provided a risk informed assessment ensures continued plant operation results in acceptable risks. Design basis configuration control is ensured by the proposed backstop CT.

The pilot system selected for implementation of this effort is NUREG 1432 TS 3.5.2, "ECCS -

Operating," relating to HPSI System operability. This TS is selected for three reasons. First, the HPSI system is a highly risk significant ECCS mitigation system for Pressurized Water Reactors (PWR) and hence must be carefully monitored. Second, the HPSI system has numerous components reflecting multiple system functions and mitigation capabilities; thus, degraded performance or partial inoperabilities within a subsystem does not imply a complete loss of mitigation capability by the affected train. Many issues that would result in a declared inoperability of a HPSI subsystem may not be risk significant. Finally, the system has many components and valves which require periodic maintenance and surveillance. Non-risk significant degradations of HPSI subsystem components have lead to a forced shutdown (Reference 10.6) at one CE designed PWR and potential shutdowns at others.

The HPSI system is an integral part of the ECCS. The primary function of the HPSI system is to inject high pressure borated water into the Reactor Coolant System (RCS) following loss of inventory and reactor overcooling events. Additionally, at FCS, the HPSI system can be used for RCS cooling via once-through-cooling operations.

FCS has three HPSI pumps with the third pump considered to be an installed spare or "swing" pump. One HPSI pump is currently required to be operable on each associated 4160 V engineered safety feature bus per TS 2.3(1)f. Borated water can be directly injected into the RCS from a Safety Injection and Refueling Water Tank (SIRWT) (located outside of containment) or recirculated (following depletion of SIRWT inventory) from the containment building sump.

The operable HPSI pumps are maintained in standby and may be actuated either manually or automatically via indications of either high containment pressure or low pressurizer pressure.

Automatic actuation of ECCS components is triggered by generation of a Safety Injection Actuation Signal (SIAS).

The shutoff head of the HPSI pumps at FCS is 3180 ft. of water (Reference 10.7). Use of the medium pressure HPSI pumps provides performance capability sufficient to ensure inventory makeup to the RCS following all sizes of Loss of Coolant Accidents (LOCAs) (Reference 10.8).

Injection into the RCS is possible at several cold and hot leg locations. However, during the early phase of a LOCA, only cold leg injection is automatically initiated. Simultaneous hot and cold leg injection is required late in large LOCA sequences to prevent possible boric acid precipitation within the reactor core. Additional system design configuration information may be reviewed in Section 5.0 of the Joint Application Report (JAR) associated with this submittal (Reference 10.1).

LIC-04-0047 Page 5 Over the past several years, numerous applications have been presented to the NRC to establish risk informed CTs for a variety of systems and components. Approvals to extend the CT for an inoperable Low Pressure Safety Injection (LPSI) subsystem or an inoperable Safety Injection Tank (SIT) were obtained for many CE designed PWRs as part of a risk informed CEOG TS improvement activity.

Risk informed CT extensions were also approved separately for the inoperability of one Emergency Diesel Generator (EDG), inoperability of one train of the Containment Spray System (CSS), inoperability of selected Containment Isolation Valves (CIV), and inoperability of one battery and associated battery charger (see References 10.9, 10.10, 10.11, and 10.12). These CT extensions established risk informed fixed CTs, with the intent that risk accumulation in these intervals would be controlled via a configuration control management program. These programs have been integrated into the plant's Maintenance Rule process. HPSI unavailability is tracked and reported as a performance indicator under the NRC's Reactor Oversight Process.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

Regulatory Guide (RG) 1.177 (Reference 10.13) indicates that for permanent TS changes, incremental Core Damage Probabilities (CDPs) of 5.OE-07 per TS entry are considered very small. As illustrated in Section 6.3 of the JAR (Reference 10.1), HPSI System inoperabilities should remain within this "very small" region. In this respect, the proposed change to TS 2.3(2)b is acceptable.

The process to control resolution of inoperabilities (e.g. repair) will be consistent with NUMARC-93-01 (Reference 10.14) and its utilization will be tracked to meet the intent of RG 1.174 (Reference 10.15). Specifically, use of the flexible CT will be controlled to ensure that the resultant cumulative plant risks during the interval beyond the frontstop CT (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) will be maintained within RG 1.174 guidelines (Regions II and III) and maintained below 1.OE-05 / reactor year. In addition, when the overall incremental plant risks fall within a range of 1.01E-06 to 1.01E-05, appropriate compensatory measures or contingency actions will be established to reduce the risk significance of the current plant configuration. Associated guidance for implementation of the proposed TS change will be maintained as administrative guidance under licensee control. When implemented with the appropriate compensatory actions and risk assessment processes, this TS modification will maintain a high level of public health and safety.

LIC-04-0047 Page 6

5.0 TECHNICAL ANALYSIS

The proposed TS changes revise the existing CT requirement for the inoperability of the HPSI subsystems of the ECCS. Specifically, it is proposed that a new Condition be created to address conditions when a single inoperable HPSI subsystem cannot be returned to service within the proposed frontstop CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The current frontstop CT for a HPSI subsystem in NUREG 1432 is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In addition to the above, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frontstop CT of 2.3(2)b is proposed to be extended to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, consistent with NUREG-1432 and TSTF-424.

The primary intent of the CT extension is to allow for the risk-informed processes to be used to assess the low risk conditions resulting from various maintenance activities as justification for extending the CT period beyond the frontstop CT, should a low risk repair/activity require extended time. The proposed risk-managed TS will obviate (or significantly reduce) the need for NOEDs. This flexibility will ensure that low risk system degradations that would cause a train or subsystem to be declared inoperable can be managed and repaired/resolved in a risk informed manner.

As indicated in the risk analysis contained in WCAP-15773 (Reference 10.1), the overall risk impact associated with a single HPSI subsystem inoperability continuing beyond the frontstop CT should be found acceptable in the majority of cases. To support this evaluation, various HPSI System component inoperabilities, possible risk significant events, and plant configurations were considered. The following provides a summary of the WEC evaluation. For more detailed information, refer to the Section 6.0 of the JAR (Reference 10.1).

A HPSI subsystem consists of various components, some more risk significant than others. Such components range from injection valves, pumps seals, associated piping, the HPSI pumps, and automatic or manual circuitry associated with the pumps and automatically actuated valves.

Other than a loss of the pump itself, many inoperabilities do not result in a total loss of HPSI capability for the affected subsystem. In light of this fact, the overall risk associated with such an inoperability is generally very small compared to complete functional loss of an entire HPSI subsystem.

Because the loss or partial loss of a single HPSI subsystem may not pose a significant adverse impact to overall plant risk, the flexible CT is proposed for HPSI subsystem inoperabilities. In general, the risk impact associated with the specific HPSI inoperability will be assessed during the same 72-hour frontstop CT as currently exists within the TSs. When, following a risk assessment, the overall plant risk is found to be acceptable, plant operation may continue beyond the frontstop CT. Continual risk assessments, as appropriate, will be performed to ensure that acceptable risk conditions are maintained. Regardless of the low level of risk, plant operation in this condition may not exceed the proposed backstop CT of 30 days. Acceptability of risk will be consistent with the Maintenance Rule (Reference 10.16) in that integrated maintenance risks beyond the frontstop CT will be controlled to an incremental CDP of < 1.0E-05 (Reference 10.14). Furthermore, the integrated risk of the HPSI inoperability while in the extended CT will be controlled consistent with the guidance and conditions identified in RG 1.174. The methods

LIC-04-0047 Attachment I Page 7 of determining the associated risk to continued plant operation may vary among the CE fleet, dependent upon current site risk assessment capabilities. In all cases, a quantitative assessment is expected to be utilized whenever the capability exists to support this assessment type.

Qualitative assessments should likewise be used where appropriate to enhance quantitative assessments or establish a risk significance when detailed quantitative tools are unavailable.

When evaluating the integrated maintenance risk for the extended HPSI CT, the entire maintenance evolution is evaluated for simultaneous outage of other plant components. The results of this evaluation may require maintenance schedules to be altered in order to maintain a low risk significance for the extended HPSI CT. Additional evaluations are performed when unanticipated changes occur, such as the unintentional loss of another component important to safety or a change in plant operating conditions. In regard to the HPSI CT extension, such an evaluation of risk may impact the overall time in which the HPSI subsystem may remain out of service. Therefore, an additional Required Action and CT is proposed to ensure further equipment inoperabilities are evaluated against the original CT established in proposed Required Action 2.3(2)b(1). A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT is proposed for this new Required Action 2.3(2)b(2)(b) to perform a re-assessment of plant risk whenever other equipment becomes unavailable that may result in an increase in overall plant risk. The proposed CT provides the necessary time to re-assess risk considering the possibility that specialized PRA staff may need to be called in to assess the change in conditions. Should it be determined that the Completion Time extension is not acceptable, Required Action 2.3(2)b(2)(c) provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to either change the current plant configuration and/or establish risk management and other compensatory measures such that overall plant risk will remain acceptable for the continuation of the HPSI Completion Time extension period. This will assure risk is managed and avoid the addition of transitional risks that may occur due to other Required Actions. If overall plant risk cannot be shown to remain acceptable prior to exceeding this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, then new Condition D must be entered, which may result in plant shutdown.

Internal and external events are also considered, either quantitatively or qualitatively, as appropriate, within the capabilities of the individual sites. As indicated in Section 6.3 of the JAR supporting this submittal (Reference 10.1), the effect of internal and external events on the risk significance of single HPSI subsystem inoperabilities is negligible. However, other component failures or planned maintenance activities simultaneous to the extended HPSI CT period may require these events to be re-assessed in the overall integrated maintenance risk evaluation.

For the various accident events described in Section 6.3 of the JAR (Reference 10.1), the change in the Incremental Large Early Release Frequency (ILERF) is not a significant contributor to the risk impact of HPSI inoperabilities that extend beyond the frontstop CT. Therefore, the proposed risk assessment to be performed prior to exceeding the frontstop CT may or may not include a detailed quantitative assessment of the impact on ILERF. The decision to perform an ILERF assessment is dependent on the overall plant configuration for the time period that the extended CT is expected to exist (i.e., what other equipment is OOS that may have a non-negligible impact on ILERF) and should be based on sound engineering judgment. Again, the assessment of

LIC-04-0047 Attachment I Page 8 ILERF, when required to be performed, should be completed quantitatively whenever plant capabilities exist to do so.

The above discussion of how and when risk assessments are performed is an integral part of station operation in today's nuclear operating environment. The expectation of the NRC and the industry is to ensure plant risk is assessed whenever plant configuration changes important to safety occur and that such risk is controlled. The TS Bases are revised to provide a general acknowledgement of these expectations.

Once the extended portion of the CT has been entered, the cumulative incremental risk of the flexible CT will be estimated and tracked. This tracking will supplement the maintenance rule aggregate risk assessment and confirm that the annual incremental risk associated with implementation of the risk-managed TS concept is small per RG 1.174 (Reference 10. 15).

Compensatory measures or contingency actions developed to offset the overall plant risk associated with the extended HPSI CT vary depending upon the actual HPSI component failure or maintenance activity. Examples of compensatory measures include the establishment of temporary cooling for inoperable HPSI room cooling fans or the protection of the Auxiliary Feedwater pumps as an alternate means of core cooling for HPSI Systems that are credited as a means for once-through core cooling. Examples of contingency actions may be the development of an Operations directive to conservatively shutdown the unit upon identifying specific equipment important to safety becoming inoperable or by delaying planned maintenance currently scheduled on other equipment important to safety. Such measures are routinely practiced for all system inoperabilities that have a significant impact on plant risk and do not present a new practice or challenge to plant operations.

In addition to the above, when two or more subsystems are inoperable except for reasons other than TS 2.3(2)a or TS 2.3(2)b, and at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available, the inoperable components must be returned to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per TS 2.3(2)e. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is based on an NRC study (Ref. 10.2) using a reliability evaluation and is a reasonable amount of time to effect many repairs. An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not capable of performing their design function, or if support systems are not available. An event accompanied by a loss of offsite power and the failure of an emergency DG can disable one ECCS train until power is restored. Reference 10.17 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses. Therefore, LCO 2.0.1 must be immediately entered. A reliability analysis (Ref. 10.2) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The LCO requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train or subsystem does not necessarily render the ECCS incapable of performing its function.

LIC-04-0047 Page 9 Neither does the inoperability of two different components, each in a different subsystem, necessarily result in a loss of function for the ECCS. This allows increased flexibility in plant operations when components in opposite trains are inoperable.

Reference 10.6 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses. Therefore, LCO 2.0.1 must be immediately entered.

The proposed less restrictive Required Actions and CTs would allow the plant to complete maintenance activities at power while avoiding a potentially greater risk associated with plant shutdown as identified in WCAP-15773, Table 6.3-7 (Reference 10.1). In practice, incremental risks are managed by limiting OOS time, implementing risk important compensatory measures, periodic tracking and prospective and retrospective risk evaluations of the use of extended flexible CT. The assessment of risk takes into account both the impacts to current risk (such as other components simultaneously OOS) and the enhancements offered by compensatory measures or contingency actions. The overall impact on risk also considers the risk avoided by remaining at steady-state power operation, eliminating the shutdown transition risks that would have normally been incurred by HPSI inoperabilities that exceed the frontstop CT. These risk management factors are considered within the scope of the Maintenance Rule and are currently well established.

In summary, HPSI system inoperabilities are recognized as playing an important role in managing plant risks. Nevertheless, sufficient programs consistent with the guidance of the Maintenance Rule may be utilized to ensure HPSI system inoperabilities can be effectively resolved without placing the plant in an unreasonable or unnecessary risk configuration. Use of the extended HPSI CT will require the plant staff to manage the inoperability in a manner consistent with a quantitative or semi-quantitative (blended) implementation of the Maintenance Rule. That is, the plant staff will assess and manage risk, and define compensatory measures as appropriate. In accordance with the philosophy for permitting limited duration inoperability of equipment, the available redundant HPSI subsystem provides adequate defense-in-depth during the period when one HPSI subsystem is inoperable. Additional guidance to evaluate simultaneous outages of multiple simultaneous component inoperabilities in conjunction with a HPSI subsystem further enhances defense-in-depth by ensuring the core cooling capability are adequately controlled. Therefore, the proposed revision to TS 2.3 and its associated Bases is acceptable as it maintains an adequate margin to safety based on risk-informed insights while avoiding unnecessary shutdown risks to repair low risk or risk insignificant inoperabilities.

6.0 REGULATORY ANALYSIS

The proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any GDC or the FCS Updated Safety

LIC-04-0047 Attachment I Page 10 Analysis Report (USAR) Appendix G. FCS was issued a construction permit prior to May 21, 1971, and therefore the GDC is based upon the plant-specific design criterion documented in Appendix G of the FCS USAR (Reference 10.18). These changes will ensure that proper limiting conditions for operation are entered for equipment or functional inoperability. The approval of this change will maintain conformance with 10 CFR50.36 and 10 CFR 50.65 (Reference 10.16).

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION The proposed change will revise Technical Specification (TS) 2.3 to provide a flexible Completion Time (CT) and associated Required Actions for inoperabilities related to a single subsystem of High Pressure Safety Injection (HPSI). This change is necessary to avoid unnecessary plant shutdowns and the subsequent incurrence of transition risks due to HPSI subsystem inoperabilities that do not present a significant adverse impact to overall plant risk. In addition, the proposed change implements a portion of the NRC and industry efforts to established risk-informed regulation as a tool to enhance the safety and welfare of the plant and the general public. Furthermore, a restoration period is provided for multiple subsystem inoperabilities provided the 100% Emergency Core Cooling System (ECCS) flow equivalent of one train is maintained.

The proposed change has been evaluated as to whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance 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 change does not require any physical change to any plant systems, structures, or components nor does it require any change in systems or plant operations; thus the probability of an accident previously evaluated occurring remains unchanged.

The proposed change does not require any change in safety analysis methods or results.

A single HPSI subsystem inoperability is considered in existing plant analyses and regulatory criteria with respect to single failure criteria and the risk of extended HPSI subsystem outages are assessed in accordance with the Maintenance Rule. Because risk is appropriately managed and compensatory measures established where necessary, the consequences of an accident previously analyzed are not significantly increased. The change to establish the extended HPSI CT limits is justified because operation within the requirements of the Maintenance Rule continues to be governed by the current regulation and plant programs.

LIC-04-0047 Page 11 Therefore, the proposed 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.

HPSI System inoperabilities are assumed in existing analyses with respect to single failure criteria and are limited by existing regulation. Extending the time in which a HPSI component may remain inoperable does not constitute a change that could result in a new type of accident initiator than that previously identified. In addition, overall plant risk will be managed in accordance with the Maintenance Rule to help ensure continued safe plant operation.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change does not require any change in accident analysis methods or results. Overall plant risks will continue to be appropriately managed and compensatory measures established when appropriate to reduce the overall risk during extended HPSI CT periods. In addition, an evaluation of common cause failure and a determination of the flow capacity of remaining ECCS components will continue to be performed in relation to HPSI System inoperabilities. Although components important to safety have an impact on overall plant risk and may impact the overall margin to safety, the adverse impacts that are realized due to single HPSI subsystem inoperabilities is largely offset by the avoidance of unnecessary shutdown transition risks and the establishment of compensatory measures and contingency actions where appropriate.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, the proposed amendment 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.

LIC-04-0047 Page 12 8.0 ENVIRONMENTAL EVALUATION The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

9.0 PRECEDENT None

10.0 REFERENCES

10.1 WCAP-15773, "Joint Application Report for the Implementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System,"

10.2 NRC Memorandum to V. Stello, Jr., from R. L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975 10.3 "Risk Informed Technical Specification: Project Description," NEI, June 2001.

10.4 TSTF 358, Revision 6, "Missed Surveillance Requirements," September 2001.

10.5 TSTF 359, Revision 6, "Increase Flexibility in Mode Restraints," October 8, 2001.

10.6 LER #94-005-01, Palo Verde Unit 2.

10.7 FCS Updated Safety Analysis Report, Table 6.2-2 10.8 CE-NPSD-593, "Partial Response to NRC Generic Letter 89-19: Small Break LOCA Recovery with Low Head HPSI," CEOG Task 651, CE Owners' Group, October 1990.

10.9 CENPSD-1045-A, "Joint Application Report: Modifications to Containment Spray System Technical Specifications," CE Owner's Group, March 1998.

10.10CE-NPSD-996, "Joint Applications Report: Emergency Diesel Generator AOT Extensions," CE Owner's Group, June 1995.

LIC-04-0047 Page 13 10.11CE-NPSD-1168-A, Revision 00, "Joint Applications Report for Containment Isolation Valve AOT Extension," CE Owner's Group, January 2001.

10.12 CE-NPSD-1 184-A, Revision 00, "Joint Application Report for DC Power Source Allowed Outage Time Extension," CEOG, May 2001.

10.13 RG 1.177, "An Approach for Risk Informed Decisionmaking: Technical Specifications,"

USNRC, August 1998.

10.14NUMARC-93-01, Revision 3, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," NEI, July 2000.

10.15 RG 1.174, "An Approach for using Probabilistic Risk Assessment in Risk Informed Decisionmaking on Plant Specific Changes to the Licensing Basis," USNRC, July 1998.

10.16 10 CFR 50.65, Appendix A, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," NRC, July 10, 1991 (56FR41324) and July 19, 1999 (64FR38551) 10.17 IE Information Notice No. 87-01, January 6, 1987.

10.18 FCS USAR Appendix G

LIC-04-0047 Page 1 ATTACHMENT 2 Markup of Technical Specification Pages

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergencv Core Cooling System Applicability Applies to the operating status of the emergency core cooling system.

Obiective To assure operability of equipment required to remove decay heat from the core.

Specifications (1) Minimum Requirements The reactor shall not be made critical unless all of the following conditions are met:

a. The SIRW tank contains not less than 283,000 gallons of water with a boron concentration of at least the refueling boron concentration at a temperature not less than 50'F.

b. One means of temperature indication (local) of the SIRW tank is operable.

c. All four safety injection tanks are operable and pressurized to at least 240 psig and a maximum of 275 psig with tank level of at least 116.2 inches (67%) and a maximum level of 128.1 inches (74%) with refueling boron concentration.

d. One level and one pressure instrument is operable on each safety injection tank.

e. One low-pressure safety injection train is operable on each associated 4,160 V engineered safety feature bus.

f. One high-pressure safety injection rain pump is operable on each associated 4,160 V engineered safety feature bus.

g. Both shutdown heat exchangers are operable.

h. Piping and valves shall be operable to provide two flow paths from the SIRW tank to the reactor coolant system.

i. All valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. HCV-2914, 2934, 2974, and 2954 shall have power removed from the motor operators by locking open the circuit breakers in the power supply lines to the valve motor operators.

FCV-326 shall be locked open.

2.3 - Page 1 Amendment No. 17,32,43,103,117,

<19,133,11,157,175,217,221

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergencv Core Cooling System (Continued)

(1) j. One high pressure safety injection pump is opc Fable on leach safety injcction rcfueling wator tark containment m ump headr.

2.3 - Page 2 Amendment No. a4

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System (Continued)

(2) Modification of Minimum Requirements During power operation, the Minimum Requirements may be modified to allow one of the following conditions to be true at any one time. If the system is not restored to meet the minimum requirements within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the minimum requirements are not met within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. One low-pressure safety injection train may be inoperable provided the train is restored to operable status within seven (7) days.

b. One high-pressure safety injection in pump may be inoperable provided the Rowing iso~ pump is rostored to operable status within 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />.

(1) n~reito-o intoerstatus within 7 urs-. ,

- OR - I; (2) .-,Perform all of the following:

(a) Determine that a Completion Time extension beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is

..'acceptable withi n 72 hou'rs.  :

(b) Verify that a Completion Timn extension beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> remains- -

'acceptable within' 24 .hours from discovery of each configuration ch ange;

'that may increase overall plant risk.

(c) Performrrisk management actions to make a Completion Time,.-.-

extensionacceptable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a Cnmpletion .

Time exten'sio'n'beyon'dhours is not a-cceptable.

) re the train-to-operable'status within 30daysora acceptable

--Comrpetion Iimejwhichever is less.-

c. One shutdown heat exchanger may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

d. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component.

e. ITw .'ormtore ECCS'train's`may bide inoperable-for reasoins othertha 2.3(?)

2TS a.

a[ 2.3(2)b p+/-ovided tha storetoople statu within4hours! Any valvn;terlock or piping associated- wiA;th the safetes injor;en and shutdown cooling system Which es not cemered under d. above but which is required to

function during accident conditions may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. One safety injection tank may be inoperable for reasons other than g. or h. below for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

g. Level and/or pressure instrumentation on one safety injection tank may be inoperable for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

h. One safety injection tank may be inoperable due to boron concentration not within limits for a period of no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

if. I less t~ahan 100%o6f the ,ECCS fl~o-w -e-q-uivalen6t to a si~ngle ope-rablIe traini is L ava ilale,`then nt Teclhnical. i 2.3 - Page 3Amendment No. 49,171,175,186,206,217, 223

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System (Continued)

Withi one 'HPSI tr-a'in -inbpera6ble6 actibnfiust'bea t~k66 tOrestore ift6tOPERABLE_..,

status within 72'hours' or a' risk-informed analysis performed . detemine'that the risk-of continued operation in the current plant configuration is acceptable for :

extending -theCompletion 'Time beyond 72 hou'rs. Inaddition, this evaluation 'ust be'performed following the'initial-72-hour.period whenever'plant configuration changes occur-that may result in a'n overall increase in plant risk. '.-The 72-hour Completion Timelis based on an' NRC study (Ref. 10) using a reliability evaluationi assuming one non-functionai HPSi train and is a reasonable amount of time to effect most repairs. However, depending'o n the' plant configuration at the tim'e of the HPSI:.

train inoperability, .the risk' of ~continued 'operatio'n may be justified 'via'- a risk-inforrmed i analysis~that follows the guidance infaccordance with'10 'ICFR50.65(a)(4) (Ref.' 11).

and is consistent with NUMARC'93-01, Section:11,Rev. 3 (Ref. .12), asboutlined in RG 1.182 (Ref. :13). This'allowanceijs based on the justification provided in WCAP-15773 (Ref.14) and the implementation of risk management guidance consistent ith., Reference'5.

.Reference.. :15demonstrates

. ... , .d ... 'n `,'1.;-a m o that the. risk can be managed and describes the analyses and'any 'management actions-necessary to utilize the:

extended Completion Time'. Exten'sion of the Completion Tine is based on acknowledgement'that many.HPSl system components are not risk-significant arnd.

that adequate tools and controls'are in place'for evaluating plant 1 risks, implementing risk-informed actio'n's', and making-approp'riate risk-informed decisions.

e'risk-in'formed 'Completion Trime establishe dby Required ;Action 2.3(2)b(2j)(a).-tah ustmtbeb updae dated whnver equipment'isredbe a s rendered unavailable thatmay increase the bverall plant risk in acco'rda'nce with Reque ired Action 2.3(2)b(2)(b). -The' overall assessment of riskp'erformrnedduring the'72-hour Completion Time'of.Required.-:-

Action 2.3(2)b(2j(a) an'd ,subsequent assessments performed under Required Action'

.3(2)b(2)(b)'should include a quantitative evaluation whenever possible.' Qualitative evaluations should:be performed to enhanice assessmenets performed quantitatively,;

or'to determnine the overall plant'riskwheriquantitative'tools are'not available. -The ':

verall assessment of risk may credit considerations given to established compensato'ry. me'asure's, continig'ency ac'ti 'onis,and avoida'nceof sh'utdow'n' :

transitional risks, -among others.. The 24' hour Completion Time of Required Action 23(2)b(2)(b) is sufficient to evaluate th'e risk impact of such configuration changes.

Should'it'be determined that the'extenrided Completion Time n is 'not acceptable, the 24 our'Coirripleti6n .Time' of 'Req'luire'd A'ction 2.3(2)b(2)(c) provides time'toestablish.. -'.

compensatory measures or. recover from -undesirable plant configurations so that the verall plant' risk will remain acceptable while in the extended Completion Time. This:

2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period is acceptable-because risk managementia-'tions, such as plant' configuration changes, operatortraining; and process 'changes will be implemented.:j, hich will reduce plant 'risk'.Regardlessof the a'cceptability'of the evaluated risk .--:

rmpact, the inoperablePSitrain 'must be'returned'toOPERABLE statu's within a naximum-of30 'days. Thiis' ma'ximum limit provides'sufficient time'to complete' repairs'while taking into'accou'nt HPSI system operational goals and 'provides for,a return to a configurationas des'cribed inthe'deterministic accident analysis.'.'

-E ' . ' ,*

References (1) USAR, Section 14.15.1 (2) USAR, Section 6.2.3.1 (3) USAR, Section 14.15.3 (4) USAR, Appendix K (5) Omaha Public Power District's Submittal, December 1, 1976 (6) Deleted (7) USAR, Section 4.4.3 (8) CE NPSD-994, "CEOG Joint Applications Report for Safety Injection Tank AOT/SIT Extension," May 1995.

(9) CE NPSD-995, "CEOG Joint Applications Report for Low Pressure Safety Injection System AOT Extension," May 1995.

(10-r taVnStll,Jrfrom R.1L.Baer, -"ReomndItri

.- .Revisions to LCOs'for'ECCSComponents," December 1,1975.

( 1) -. CFR .

h10 .65(a)(4)-

(12) :NUMARC 93-01, ilndustry'Guideline for Monitoring the Effectiveness' of

'-'Maintenance at Nuclear'ePiower Plants,". Revision 3.'

(3) 'RG .1.182,-Assessing' and ManagingRisk Before Maintenance'Activities at (14, ,,W,Nuclear Power Plants," May 2000.'-

A' '

(14); WCAP-.1 5773 Joint Application Report for the' lmplementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System," August 2002.- -

(ik5) lNsManagement TechknicalSpifications, Risk Manage nt'Guide 2.3 - Page 7 Amendment No. 17,61,74,179, 206, 217,

LIC-04-0047 Page 1 ATTACHMENT 3 Proposed Technical Specification Pages (clean)

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System Applicability Applies to the operating status of the emergency core cooling system.

Obiective To assure operability of equipment required to remove decay heat from the core.

Specifications (1) Minimum Requirements The reactor shall not be made critical unless all of the following conditions are met:

a. The SIRW tank contains not less than 283,000 gallons of water with a boron concentration of at least the refueling boron concentration at a temperature not less than 50 0F.

b. One means of temperature indication (local) of the SIRW tank is operable.

c. All four safety injection tanks are operable and pressurized to at least 240 psig and a maximum of 275 psig with tank level of at least 116.2 inches (67%) and a maximum level of 128.1 inches (74%) with refueling boron concentration.

d. One level and one pressure instrument is operable on each safety injection tank.

e. One low-pressure safety injection train is operable on each associated 4,160 V engineered safety feature bus.

f. One high-pressure safety injection train is operable on each associated 4,160 V engineered safety feature bus.

g. Both shutdown heat exchangers are operable.

h. Piping and valves shall be operable to provide two flow paths from the SIRW tank to the reactor coolant system.

i. All valves, piping and interlocks associated with the above components and required to function during accident conditions are operable. HCV-2914, 2934, 2974, and 2954 shall have power removed from the motor operators by locking open the circuit breakers in the power supply lines to the valve motor operators.

FCV-326 shall be locked open.

2.3 - Page 1 Amendment No. 17,32,13,103,117, 119,133,141,157,175,217,221

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Coolinq System (Continued)

(2) Modification of Minimum Requirements During power operation, the Minimum Requirements may be modified to allow one of the following conditions to be true at any one time. If the system is not restored to meet the minimum requirements within the time period specified below, the reactor shall be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If the minimum requirements are not met within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the reactor shall be placed in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. One low-pressure safety injection train may be inoperable provided the train is restored to operable status within seven (7) days.

b. One high-pressure safety injection train may be inoperable provided the following is performed:

(1) Restore the train to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

OR (2) Perform all of the following:

(a) Determine that a Completion Time extension beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(b) Verify that a Completion Time extension beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> remains acceptable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of each configuration change that may increase overall plant risk.

(c) Perform risk management actions to make a Completion Time extension acceptable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery that a Completion Time extension beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is not acceptable.

(d) Restore the train to operable status within 30 days or an acceptable Completion Time, whichever is less.

c. One shutdown heat exchanger may be inoperable for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

d. Any valves, interlocks or piping directly associated with one of the above components and required to function during accident conditions shall be deemed to be part of that component and shall meet the same requirements as listed for that component.

2.3- Page 2 Amendment No. 4,7-,-1,17-1,175,186,2O6,21-

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System (Continued)

e. Two or more ECCS trains may be inoperable for reasons other than TS 2.3(2)a or TS 2.3(2)b provided that they are restored to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

f. One safety injection tank may be inoperable for reasons other than g. or h. below for a period of no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

g. Level and/or pressure instrumentation on one safety injection tank may be inoperable for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

h. One safety injection tank may be inoperable due to boron concentration not within limits for a period of no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

i. If less than 100% of the ECCS flow equivalent to a single operable train is available, then enter Technical Specification 2.0.1.

2.3 - Page 3 Amendment No. 49,171,175,186,206,2'17, 223

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System (Continued)

With one HPSI train inoperable, action must be taken to restore it to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or a risk-informed analysis performed to determine that the risk of continued operation in the current plant configuration is acceptable for extending the Completion Time beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In addition, this evaluation must be performed following the initial 72-hour period whenever plant configuration changes occur that may result in an overall increase in plant risk. The 72-hour Completion Time is based on an NRC study (Ref. 10) using a reliability evaluation assuming one non-functional HPSI train and is a reasonable amount of time to effect most repairs. However, depending on the plant configuration at the time of the HPSI train inoperability, the risk of continued operation may be justified via a risk-informed analysis that follows the guidance in accordance with 10 CFR 50.65(a)(4) (Ref. 11) and is consistent with NUMARC 93-01, Section 11, Rev. 3 (Ref. 12), as outlined in RG 1.182 (Ref. 13). This allowance is based on the justification provided in WCAP-1 5773 (Ref. 14) and the implementation of risk management guidance consistent with Reference 15. Reference 15 demonstrates that the risk can be managed and describes the analyses and any management actions necessary to utilize the extended Completion Time. Extension of the Completion Time is based on acknowledgement that many HPSI system components are not risk-significant and that adequate tools and controls are in place for evaluating plant risks, implementing risk-informed actions, and making appropriate risk-informed decisions.

The risk-informed Completion Time established by Required Action 2.3(2)b(2)(a) must be updated whenever equipment is rendered unavailable that may increase the overall plant risk in accordance with Required Action 2.3(2)b(2)(b). The overall assessment of risk performed during the 72-hour Completion Time of Required Action 2.3(2)b(2)(a) and subsequent assessments performed under Required Action 2.3(2)b(2)(b) should include a quantitative evaluation whenever possible. Qualitative evaluations should be performed to enhance assessments performed quantitatively or to determine the overall plant risk when quantitative tools are not available. The overall assessment of risk may credit considerations given to established compensatory measures, contingency actions, and avoidance of shutdown transitional risks, among others. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time of Required Action 2.3(2)b(2)(b) is sufficient to evaluate the risk impact of such configuration changes. Should it be determined that the extended Completion Time is not acceptable, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time of Required Action 2.3(2)b(2)(c) provides time to establish compensatory measures or recover from undesirable plant configurations so that the overall plant risk will remain acceptable while in the extended Completion Time. This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is acceptable because risk management actions, such as plant configuration changes, operator training, and process changes will be implemented which will reduce plant risk. Regardless of the acceptability of the evaluated risk impact, the inoperable HPSI train must be returned to OPERABLE status within a maximum of 30 days. This maximum limit provides sufficient time to complete repairs while taking into account HPSI system operational goals and provides for a return to a configuration as described in the deterministic accident analysis.

2.3 - Page 7 Amendment No. 17,64,71,179, 206, 217, I

2.0 LIMITING CONDITIONS FOR OPERATION 2.3 Emergency Core Cooling System (Continued)

References (1) USAR, Section 14.15.1 (2) USAR, Section 6.2.3.1 (3) USAR, Section 14.15.3 (4) USAR, Appendix K (5) Omaha Public Power District's Submittal, December 1, 1976 (6) Deleted (7) USAR, Section 4.4.3 (8) CE NPSD-994, "CEOG Joint Applications Report for Safety Injection Tank AOT/SIT Extension," May 1995.

(9) CE NPSD-995, "CEOG Joint Applications Report for Low Pressure Safety Injection System AOT Extension," May 1995.

(10) NRC Memorandum to V. Stello, Jr., from R. L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.

(11) 10 CFR 50.65(a)(4).

(12) NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3.

(13) RG 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," May 2000.

(14) WCAP-1 5773, "Joint Application Report for the Implementation of a Risk Management Technical Specification for the High Pressure Safety Injection (HPSI) System," August 2002.

(15) Risk Management Technical Specifications, Risk Management Guide 2.3 - Page 8 Amendment No. 17,61,71,170, 206, 217