Text

License Amendment Request Applicable to TSs Surveillance Requirement 3.0.3, Missed Surveillance, and Associated Bases, Using the Consolidated Line Item Improvement Process
	ML021190479
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	04/16/2002
From:	Tuckman M; Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML021190479 (44)
	v • d • e

Duke Duke Power 526 South Church St. EC07H WEr~wWeN Charlotte, NC 28202 A Duke Energ Company P.O. Box 1006 EC07H Charlotte, NC 28201-1006 (704) 382-2200 OFFICE M. S. Tuckman FAX (704) 382-4360 Executive Vice President Nuclear Generation April 16, 2002 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Duke Energy Corporation Oconee Nuclear Station Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 License Amendment Request Applicable to Technical Specifications Surveillance Requirement 3.0.3, Missed Surveillance, and Associated Bases, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10CFR50.90, Duke Energy Corporation (Duke) is submitting a request for an amendment to the Technical Specifications (TS) for Oconee Nuclear Station (ONS) Units 1, 2, and 3; McGuire Nuclear Station (MNS) Units 1 and 2; and Catawba Nuclear Station (CNS) Units 1 and 2. This amendment request is consistent 1 2 The with two recent NRC Federal Register notices. '

proposed amendment would modify the TS requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3 and associated Bases. In conjunction with the proposed change, the Federal Register notice also stated that requirements for a Bases Control Program, consistent with the TS Bases Control Program described in Section 5.5 of the applicable vendor's standard TS, shall be incorporated

' 66FR 32400, June 14, 2001, "Notice of Opportunity to Comment on Model Safety Evaluation, Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process."

2 66FR49714, September 28, 2001, "Notice of Availability of Model Application Conceming Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process."

U. S. Nuclear Regulatory Commission April 16, 2002 Page 2 into the licensee's TS, if not already in the TS. Since ONS, MNS, and CNS have already converted to the Improved Technical Specifications, each of these plants has an approved Bases Control Program in place. Consequently, it is not necessary to propose any changes to the Bases Control Program within this license amendment request for either of the Duke plants. Please note that in a recent license amendment request submittal dated December 20, 2001, Duke proposed an administrative change to make the Bases Control Program requirements of ONS, MNS, and CNS TS Section 5.5 consistent with the recently revised 10 CFR 50.59 regulation. This license amendment request is currently undergoing NRC review.

The contents of this submittal package are as follows:

" Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications.

"* Attachments 2a, 2b, and 2c provide the existing TS and Bases pages for ONS Units 1, 2, and 3; MNS Units 1 and 2; and CNS Units 1 and 2, respectively. These marked copies show the proposed changes.

"* Attachments 3a, 3b, and 3c provide the revised (clean) TS and Bases pages for ONS Units 1, 2, and 3; MNS Units 1 and 2; and CNS Units 1 and 2, respectively.

"* Attachment 4 provides a summary of the regulatory commitments made in this submittal.

As listed in Attachment 4, implementation of this proposed change in the TS will require revision to the MNS and CNS Updated Final Safety Analysis Reports (UFSAR). These revisions will be made in accordance with applicable regulations. No changes were identified as being necessary for the ONS UFSAR. Duke is requesting NRC review and approval of this submittal by October 15, 2002. Duke is 3 1 OCFR50.7 1, "Maintenance of records, making of reports."

U. S. Nuclear Regulatory Commission April 16, 2002 Page 3 also requesting a 90-day grace period to implement this amendment.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, the site-specific changes contained in this proposed amendment have been reviewed and approved by the applicable ONS, MNS, or CNS Plant Operations Review Committee. This proposed amendment has also been reviewed and approved by the Duke Nuclear Safety Review Board. Pursuant to 10CFR50.91, a copy of this amendment request is being sent to the designated official of the State of North Carolina and the designated official of the State of South Carolina.

Inquiries on this matter should be directed to J. S. Warren at (704) 382-4986.

Very truly yours, M. S. Tuckman Attachments:

1. Description and Assessment

2. Proposed Technical Specifications Changes

3. Revised Technical Specifications Pages

4. Regulatory Commitments

U. S. Nuclear Regulatory Commission April 16, 2002 Page 4 xc w/Attachments:

L. A. Reyes U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan (Addressee Only)

NRC Senior Project Manager (ONS)

U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 C. P. Patel (Addressee Only)

NRC Senior Project Manager (CNS)

U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 R. E. Martin (Addressee Only)

NRC Senior Project Manager (MNS)

U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 M. E. Shannon Senior Resident Inspector (ONS)

U. S. Nuclear Regulatory Commission Oconee Nuclear Site D. J. Roberts Senior Resident Inspector (CNS)

U. S. Nuclear Regulatory Commission Catawba Nuclear Site S. M. Shaeffer Senior Resident Inspector (MNS)

U. S. Nuclear Regulatory Commission McGuire Nuclear Site

U. S. Nuclear Regulatory Commission April 16, 2002 Page 5 R. Wingard Division of Radioactive Waste Management South Carolina Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201 M. Frye Division of Radiation Protection 3825 Barrett Drive Raleigh, NC 27609-7221

U. S. Nuclear Regulatory Commission April 16, 2002 Page 6 M. S. Tuckman, affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

M. S. Tuckman, Executive Vice President Subscribed and sworn to Date 1 Notary Public M cohsQC Cres o expi.

My commission expires: jThiuaV 22- 2oo3 SEAL MICHAEL T. CASH Notary Public Lincoln County, North Carolina Commission Expires January 22, 2003

U. S. Nuclear Regulatory Commission April 16, 2002 Page 7 bxc w/Attachments:

M. T. Cash C. J. Thomas G. D. Gilbert L. E. Nicholson K. L. Crane K. E. Nicholson J. E. Smith J. M. Smith (2)

N. T. Clarkson L. J. Rudy P. T. Vu NRIA File/ELL Oconee Master File - ON03DM (File OS 801.01)

McGuire Master File - MG01DM Catawba Master File 801.01 - CN04DM Catawba Owners:

Saluda River Electric Corporation P. 0. Box 929 Laurens, SC 29360-0929 NC Municipal Power Agency No. 1 P. 0. Box 29513 Raleigh, NC 27626-0513 T. R. Puryear NC Electric Membership Corporation CN03G Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651

Attachment 1 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify the Oconee Nuclear Station (ONS), McGuire Nuclear Station (MNS), and Catawba Nuclear Station (CNS) Technical Specifications (TS) requirements for missed surveillances contained in Surveillance Requirement (SR) 3.0.3. The changes are consistent with an NRC-approved Industry Technical Specifications Task Force (TSTF) Standard TS Traveler.'

The availability of this TS improvement opportunity has been 3

published in the Federal Register. 2 ' The Bases applicable to SR 3.0.3 are also being revised consistent with the referenced industry traveler and Federal Register notices. The revised Bases are included in this amendment submittal package.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Duke Energy Corporation (Duke) has reviewed the safety evaluation dated June 14, 2001 as part of the NRC's Consolidated Line Item Improvement Process (CLIIP) 2 . This review included a review of the NRC Staff's evaluation as well as the supporting 1 . Duke has determined that the information for the TSTF justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC Staff are applicable to ONS Units 1, 2, and 3; MNS Units 1 and 2; and CNS Units 1 and 2. Further, Duke has determined these discussions justify implementation of the changes proposed in this amendment request at ONS, MNS, and CNS.

2.2 Optional Changes and Variations Duke is not proposing any variations or deviations from the TS changes described in the TSTF 1 or from the NRC's model safety evaluation as published in the Federal Register.2 1TSTF-358, Revision 6, entitled "Missed Surveillance Requirements."

2 66FR 32400, June 14, 2001, "Notice of Opportunity to Comment on Model Safety Evaluation, Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process."

3 66FR49714, September 28, 2001, "Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process."

1

Attachment 1 Description and Assessment

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Duke has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLIIP. Duke has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to ONS, MNS, and CNS and is hereby incorporated 4 5 by the applicable regulations. '

reference to satisfy 3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register, 3 plant-specific verifications were performed as follows:

" Duke has established TS Bases for SR 3.0.3 which state that use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.

" The modification will also include changes to the Bases for SR 3.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals, but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that Duke is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analyses assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the 6

program in place to implement the applicable regulation, and "410 CFR 50.91, "Notice for public comment; State consultation."

5 10 CFR 50.92, "Issuance of amendment."

6 10 CFR 50.65(a)(4), "Requirements for monitoring the effectiveness of maintenance at nuclear power plants."

2

Attachment 1 Description and Assessment its implementation guidance, 7 and that the missed surveillance should be treated as an emergent condition, as discussed in this regulatory guide. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, Duke has an approved Bases Control Program already in place at ONS, MNS, and CNS that was implemented during these plants' conversion to the Improved Technical specifications.

4.0 ENVIRONMENTAL EVALUATION Duke has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001 as part of the CLIIP. Duke has determined that the NRC Staff's findings presented in that evaluation are applicable to ONS, MNS, and CNS and the evaluation is hereby incorporated by reference for this application.

7 Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants."

3

Attachment 2a Oconee Nuclear Station Units 1, 2, and 3 Proposed Technical Specifications Changes Marked Copy

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

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

Insert 2 While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Insert 3 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and the risk impact shall be managed.

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

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

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

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, u to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever i This delay period is permitted to allow performance of the Surveillance.

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

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

OCONEE UNITS 1, 2, & 3 3.0-3 Amendment Nos. i 0,y I*

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

These exceptions are stated in the individual Specifications. An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of "in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions." The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations.

Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."

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

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

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

This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

OCONEE UNITS 1, 2, & 3 B 3.0-12 Amendment Nos. 0, 00A 0

SR Applicability B 3.0 BASES SR 3.0.3 The basis for this delay period includes consideration of unit conditions, (continued) adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

hen aSurveillanmwith a Frequicy based notAn time interval but Fupon have/ ecified en unF:nditions performed when speor fied,rational SR 3.0.3/allows is discovred situ tions, the not to full d lay period If a ours notporm w lance. te lurvii ae tthime nsequenced foe completion Surveillancerthat become pplicable as a tMODE chaif ges imposed t y Required Acoions.nf Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is S~to a flexibility extend Surveillance intended to be used as an operational convenience which is not intervals..*

If a not completed within the allowed delay period, then the is Surveillance equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Satisfactory completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

OCONEE UNITS 1, 2, & 3 B 3.0-13 Amendment Nos.3-,3,&00

Attachment 2b McGuire Nuclear Station Units 1 and 2 Proposed Technical Specifications Changes Marked Copy

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

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

Insert 2 While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Insert 3 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and the risk impact shall be managed.

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

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

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

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, u to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is This delay period is permitted to allow performance of the Surveillance.

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

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

(continued)

McGuire Units 1 and 2 3.0-4 Amendment Nos. ý

SR Applicability B 3.0 BASES SR 3.0.2 (continued)

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

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

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

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

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the/

required Surveillance, and the recognition a result of requirements. I henthat the most probable a/Surveillance/with condit '

ns any particular with the Surveillance being performed uon is thespecifie* unitof verification conformance i ptervalsbt av enperomd*

0t on time no n Frequeny baed is dicoed 2 hav ft e rs tperfo rme the situatio'ns, o or operational lo s tl 2fllde laye n i~ 3.g. a dSR spe that oISurveillanci s

time limit for *ompletion 3.0.3 al5 S,,$b provides N o.r Revision ely c e 4h ero h B 3.0-11 U nits and 21 M cG uire

SR Applicability B 3.0 BASES SR 3.0.3 (continued)

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

XNvSPeT- 2 If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

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

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

McGuire Units 1 and 2 B 3.0-12 Revision No-/

Attachment 2c Catawba Nuclear Station Units 1 and 2 Proposed Technical Specifications Changes Marked Copy