Text

Application for Technical Specification (TS) Change - Missed Surveillances Using the Consolidated Line Item Improvement Process (Revision 1)
	ML022950112
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	10/17/2002
From:	Burzynski M; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-SQN-TS-02-04
	Download: ML022950112 (35)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 October 17, 2002 10 CFR 50.90 TVA-SQN-TS-02-04 SU.S. Nuclear Regulatory Commission

'ATTN: Document Control Desk

,Washington, D.C. 20555-0001 Gentlemen:

In the Matter of

)

Docket Nos 50-327 Tennessee Valley Authority

)

50-328 APPLICATION FOR TECHNICAL SPECIFICATION (TS) CHANGE - MISSED SURVEILLANCES USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (REVISION 1)

In accordance with the provisions of 10 CFR 50.90, Tennessee Valley Authority (TVA) submitted on September 3, 2002 a request for amendments to Sequoyah Nuclear (SQN)

Plant's license NPR-77 for Unit 1 and license NPR-79 for Unit 2. The proposed changes would modify Surveillance Requirement SQN Unit 1 and 2 to allow a delay period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the surveillance frequency interval, whichever is greater, and to require a risk analysis be performed for any surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . These changes adopt NRC-approved Technical Specification Task Force (TSTF) item TSTF 358, Revision 6. The availability of this TS improvement was published in the Federal Register (FR) on September 28, 2001 (FR Notice 66 FR 49714) as part of the Consolidated Line Item Improvement Process (CLIIP). This submittal also contained proposed change packages for Browns Ferry Nuclear Plant's license DPR-33 for Unit 1, license DPR-52 for Unit 2, license DPR-68 for Unit 3, and Watts Bar Nuclear Plant's license NPF-90.

Pnnted on recycled paper

U.S. Nuclear Regulatory Commission Page 2 October 17, 2002 Due to the vintage of SQN's TS, incorporation of this CLIIP will entail additional changes.

For SQN Units 1 and 2, TVA, in the September 3, 2002 submittal, proposed three separate changes to their TS: (1) to modify the wording of the current SR 4.0.1 and 4.0.3 to be consistent with NUREG-1431, Revision 2, wording for SR 3.0.1 and SR 3.0.3; (2) to modify the current TS 6.8, adding a new subsection 6.8.j, which will include the NUREG 1431, Revision 2, wording for TS 5.5.14 which discusses the TS Bases Control Program; and (3) to modify the Improved Standard TS wording, adopted in item 1 above, to allow a delay period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the surveillance frequency interval, whichever is greater, and to require a risk analysis to be performed for any surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (TSTF 358, Revision 6). In adopting the NUREG-143, Revision 2, TS Bases Control Program, SQN will also conform to the Improved STS wording adopted in TSTF-364, Revision 1, that had already been incorporated into NUREG-1431, Revision 2.

During the review of the above discussed submittal, questions were raised about some NUREG 1431, Revision 2 omitted sections within the proposed bases for SR 4.0.1 for SQN Unit 1 and Unit 2. These sections had been omitted for the TVA September 3, 2002 submittal to be consistent with existing precedence from a December 10, 2001, STP Nuclear Operating Company amendment change for South Texas Project Units 1/2 licenses and a July 19, 2002 Nuclear Management Company amendment change for Kewaunee Unit 1. A revision to the SQN submittal to include these omitted sections was requested in a teleconference held on October 16, 2002 with the NRC/NRR reviewer.

The revised submittal includes the omitted sections of the NUREG 1431, Revision 2, SR 3.0.1 Bases as part of the proposed SQN Unit 1 and 2 SR 4.0.1 Bases. Slight changes were necessary in the adoption of the these sections into SQN's TS due to the difference in terminology that has been adopted with the Improved STS. Also revised in this submittal is a typographical error in a TS section reference in the last sentence of the proposed TS 4.0.3 bases.

A revised Enclosure 6 and 7 is provided that contains copies of the appropriate TS and Bases pages marked to show the proposed change. Revised Enclosures 12 and 13 forward the revised TS and Bases pages which incorporate the proposed change.

TVA has determined that these revisions do not impact the previous no significant hazards considerations or environmental review exemption transmitted in the September 3, 2002 submittal. Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Tennessee State Department of Public Health.

U.S. Nuclear Regulatory Commission Page 3 October 17, 2002 There are no commitments contained within this submittal.

If you have any questions about this change, please contact Susan Ferrell at (423) 751-7737.

Pursuant to 28 U.S.C. § 1746 (1994), I declare under penalty of perjury that the foregoing is true and correct. Executed on this 17th day of October 2002.

Sincerely, Mark rzynski Manager Nuclear Licensing Enclosures cc (Enclosures).

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-8931 Mr. R. W. Hernan, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08G9 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, TN 37379-3624 Mr. Lawrence E. Nanney, Director TN Dept. of Environmental & Conservation Division of Radiological Health 3 Floor, LNC Annex 410 Church Street Nashville, Tennessee 37243-1532

ENCLOSURE 6 (Revision 1)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SQN)

UNIT 1 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 MARKED PAGES AFFECTED PAGE LIST Page 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4 6-1OB (New Page)

Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording II.

MARKED PAGES Attached E-6-1 (9 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1.Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions spe6cified for individual Limiting Conrditions for Operation unless-otherwise stated in'an individual, Surveillance Requirement:f.--

Replace w/

Insert 1 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval W maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specificationh4.0.2, shall constitute noffcomplianve with the OPERABILITY reqlirements'fr a'Limiting *'*_

C6rodition fo'rOperati-on.The timýe lirfiits of the ACTION re-qiuirements are applicable at the'time it is identified that a Sur-veillance Requirem'ent has~n'ot 6e-en perfor*ed.,The'CT!ON requir'ernerts maybe' delayed for'up to 24 iours tope6rmfit thi completion of thfe surveillance6'when t6e'allowable outage time lirrits of the ACTION requirements ar6 lessthan 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Surveillance Requirements-do not-have to'be perfoifried on inoperable equipment-.

7, Replace w/

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Insert 2 Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be as follows:

Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports. The program shall include the following

a.

Provisions that inservice testing of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;

b.

The provisions of SR 4.0 2 are applicable to the frequencies for performing inservice inspection activities;

c.

Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c 4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section XI; and

d.

Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS March 8, 2002 SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. 78, 162, 208, 274

APPLICABILITY BASES instead, provided the other specified conditions are satisfied In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCOs 3.0.1 and 3.0.2 (e.g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs.

This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

4.0.1. This specification provides thatsurVeillance activities necessary to-insure theb Limiting Conditionhs fr Operation are met and Will b6 performed during the OPERATIONAL MODES or 6ther cdnditi6nrs forw*hich" the Limiting, Conditions'fofbOperation are applicable.- P "rovisions

for additional surveillance activities to be'*

performed without regard to-the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements 'Sur'veillance Recquir6ments for Spe'cial Test Exceptionsri'ned only be performned when the'Special Test Exception is being bitilized as'an exception'to an individual,

Specification. -.

SReplace w/Insert 3 June 13, 1995 SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78,162, 202

APPLICABILITY BASES 4.0.2 Specification 4.0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance, e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

SEQUOYAH - UNIT 1 June 13, 1995 Amendment No 78, 262, 2002 4.0.3,This specification establishes the failufre'to perform a Surveillahce Requ, iremneht within the allowed surveillance interal, 'defined by `the pirovisionis bf S'pec'ificati6-n'4.0.2,*as6a conditio'n that c6hnstitute6--

failur6 to meet the bPEFABILITYY, rquirements for a Liritirng condition for,O&e'r§ti'ioýr.Undert

ý,

provisionsof this specification', systems and components are assuim'ed lobe OPERABLE when *.:-".,,,.

Surveillance Requirements have been satisfactordly performed within the specfiedtime interval. -However, othindignthi-s *ro~'isio is to be constuedI -asimpl yingt-atl sistems or co'mpo6ients are OPERABLE-When:

they are found or kniown to be inoperable although stillmeeting the Surveillance Requirements.7This - :2 specification a'lso c;arifies that the ACTION requiremenIts are applicable whenSur'eillan'66e" Re`quirrn-ensts have not been completed within the allowe(d'surveillance intervalahnd thit thetiimre limits of the' ACTION.

iequir'emne'ts~a p-pIy friom ithe poirit in'i tim-e itis y;-:

7I rDelete I

B 3/4 0-3a

APPLICABILITY BASES I Replace w/Insert 4I May 25, 2000 Amendment No. 78 SEQUOYAH - UNIT 1 ideritified that a'sdrveillance has not been perforrmed and not-at the tinmie'thattli6'allowed surveillane-."

inteval was excbeded.' *CompIetionof the Surveillance Requireent within the allowable outage time limits of,the ACTION r'e-quirerme'nts' restores compliancewith thee'equirei*ents 6f Specification 4:0.3'i-*.-

H0we66r;.this d60s rioft'negate the6 fact that the failure to Iia-v*l*erfinred the su-rJveillance withi"rihhe- ",--,

allowed surveiliance interval, defined by the provisio-ns of Specification 4*0.2,-was a vio)lation of the OPERABILI-Y. requirements of a Limiting Cordition for Operation that is suibje't to' enforcement action.-'

If the'allowable outage'time limits -of the ACTION requirermnnt are less than 24 Iour (the allowble :

outage time limits are defined as the first timeframe encountered in th" ACTION requiremenit) r

shutdown is required to comply',with ACTION requirements, e.g.,ýSpecific6tion 3.0:3; a 24-hour allowance is provided to permit a delay~in irmlementing ihe ACTION requiremenis. Thispi'ovideIas a anIlenuate time lirit to complete'Surveillance Requir6ments-that have not been performed:*-The purpose~f this all6wrance is to permit the corfipletion of a'surveillanc'e b'efor'e a shutdowwn is -required t6ocdmply with: ACTION-..'

requireents odr* b~efo*eother r'em edial measures-w'old be 6qiiired that may prIclude*om'pletioii of a surveillance*Th. basis fortlis allowanc includes consideriti6n'fcr Plant conditions, *ud&`te'lanning, availability of personn-nelthe tim e'required to' erf6rm the surveilance, 'and the safety sighificance of the delay in eompl~ting theie'quired "surveilla nce.6 This provision lso prvidesa tin limit for the.completion-*

of Sur~eillarnce' Requirem-ents'that becorfie 'a*pliable ;as aconsequenhe bf MODE chang6sim'psed b*y ACTION 'relirersents and foriorpleting Surveillance Requirements that areaiplicable imh-ea D.,

cpti6n-to the r'equirements of Specificatioi *4:0.4 is'allowed.; If asurveillarnce isnbt c66nipleteid within the 24-ho'ur allo~nce, thetime 'imnits of 'the ACTION requir-eintierts are Iapplicable at that time. -Wh*-en a S~v~eill1ce is pe~rforrned itfhin he 24-h~ur, allowan-e "a n-d thefi SurveillahceI Reýuireie'nets are

-nt met the tim~e~limn'its ofth ACTiON reuiremert*ar*

lppiicalbleat the tim'e that the subr'eilan'& is t-erinated6 Surveillance Requiremenrts do not have to" beperformed on inop)erable equipment because the6ACTION req uirements define the remedial hieb sures that alply.,Hovvever,"the Surveillan6e Reqiuiimeneits have to:

be riiet to deri16nstrate' that inoperable -equipment ha's been restored to"OPERABLE statuds.7 f<

B 3/4 0-4

ADMINISTRATIVE CONTROLS Technical Specification (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following.

1.

A change in the TS incorporated in the license or

2.

A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d.

Proposed changes that meet the criteria of Specification 6.8.j.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e)

Inserted new Section 6.81j on new page 6-1lOb.

DATE SEQUOYAH - UNIT 1 6-1Ob Amendment No New Page

SQN 1 Technical Specification Change Inserts Insert I - TS 4.0.1 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Insert 2 - TS 4.0.3 4.0 3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.02), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

Insert 3 - Bases 4.0.1 4.0.1 SR 4 0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement. The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable. Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4 0.2, R1 constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when a

The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

E-6-7

SQN 1 Technical Specification Change Inserts - Continued Surveillances do not have to be performed when the unit is in a OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirement s associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be R1 completed Some examples of this process are:

a Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactonly completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

Insert 4 - Bases 4.0.3 4.0 3 SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit 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 surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0 2, and not at the time that the specified surveillance interval was not met.

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

The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements When a Surveillance with a surveillance 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 E-6-8

SQN 1 Technical Specification Change Inserts - Continued 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, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4.0.3 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.

Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0 3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval 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.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins 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 entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the ACTIONS, restores compliance with Specification 4.0.1.

E-6-9

ENCLOSURE 7 (Revision 1)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SQN)

UNIT 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 MARKED PAGES AFFECTED PAGE LIST Page 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4 6-7 6-7a (New Page)

Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording II.

MARKED PAGES Attached E-7-1 (10 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 *Surveillance Requirements shall be met during the OPERATIONAL MODES dr other.conditions'"

specified for individual Limiting,Cofiditio'ns~fo'r'Op-e~ratiori unlis's otherwisde tat~d in" an individual V",'

Survei~llance-Requir-em'ent.

ii-'

IReplace w/I 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with allnsert 1 maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3,Failure'to perform a Surveillanrce Requirement within the allowed surveillance'interval, "defined by, ".

Specification 4:0.2,shfall constitute noncomplianre with'the'OPERABILITYiequiremen'ts for a Limitihgo Condition for Operati6h.- The time limiis of the ACTION requik6emnnts areapplicable at th-e tib it is,.

idenrtified that'a Surveillancb R6quirement has not been performed. :The6ACTION "reqdirements maybe delayed for up to 24,hobirs to permit thle ompIletiono6f the suirveillance 'when the*alo6wable'outage tim'e,.'*

limits'of the ACTION requiremenits are less than 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:, Sdrveillanc6Requirements do not have to be,,,1 performed on inopIerable-equipment.

Replace w/

4.0 4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Insert 2 Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0 5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports. The program shall include the following:

a.

Provisions that inservice testing of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a; b

The provisions of SR 4.0 2 are applicable to the frequencies for performing inservice inspection activities;

c.

Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4 b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c.4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section XI; and d

Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS March 8, 2002 SEQUOYAH - UNIT 2 3/4 0-2 Amendment Nos 69, 152, 198,263

BASES 3.0 5 (Continued) specified conditions are satisfied. In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3 0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to 3.0 6 LCO 3.0 6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCOs 3.0.1 and 3.0 2 (e g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the operability of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

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

4.0.1 This spebification provides that surveillance activities hecedssary to insure'the Limiting Conditions for Operationare-emet -and Will be-performed,dur'ing the OPERATIONAL MODESbor other conditions fdrwhich the Limiting Conrditions for Operation are ap plicable. -Provisions for additional surveillaance'activities to0be performed without regard to the apýplicable OPERATIONAL MODES -or other c6nditions are p0o"Vided in the individual Su'rveillance'Requirements. 'Surveillance Require'ments for Special Test Exceptions~need,','

only be'pe5rformed wh'en'theý Special Test Exception' is being utilized as an exception to an individual.:

ISpecification.

Replace w/ Insert 3 June 13, 1995 SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No. 69, 152,192

APPLICABILITY BASES 4.0.2 Specification 4.0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance, e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval SEQUOYAH - UNIT 2 June 13, 1995 Amendment Nos 69, 152, 192 4.0.3

'This specification bstablishes the failure to perform a' Surveillance Requiremeht Within the allowed surveillan*ce in-te'al; defined by the pro'isiorns7 of Specification'4.0.2, as a condiiion that con'stitute-a.i faiure to meet the OPERABILITY requirements for a Limiting Condition for Operation. SUnder the' provisionsof this"specification,: systemsan components are assumed to be OPERABLE fe'n" "

SurveilIanc66Requ'ie`ir'ents hav-e been satisfactoriiy performied withirnthb'spýe6ified tirme'intrval".Howe'iever, nothing in this provis.ion i's to be construed aas'implying 'that -systems

,rcompoInehts-are OPERABLE'wheh they aref6fdnd or*know'n to'be inoperable'although still reetind the Suirveillance' Requirements:-This f>;

specification also clarifies that the ACTION requiremernts are applicable when Surveillance Requirements""

have'not been completed withinthe allowed surveillance interval and that the time limits of;th6 ACTION,

requireiments apply fromi the point in time it is identified that a surveillance has not been peformed and not at the time that the allowed 'surveillanie interval was exc6eded.-Completion of the Surveillance ',-.`_

Reqiiirem'ent within the" B 314 0-3a

BASES allowable outage time'limits of the ACTION reiquirements rdstor6s dom-plidince with the'requirements'of Specification 4'0.3.'ý,H6w-e"Ver,"this -do'-es-no't negate-,the fact thk the f6if.ure to have peirformed the surveillanb6'w-itWi'n*t4e'ýýflo"w' d surveilllance'iriter4, defined by_'ft*pr'oviii6ns of'specific'6tion 4' -, wa'--'-'

vil6lati6in'Of thii OPERABILITYieqiuir'_ ent" -- 614-6iti6-Cbndition'fo'O on that is subidct to' enforcement action.

If the allowable outage'tir6e lim-itd of the ACT6ý ieýI6iriement are" ies's--thýan' 24 ho6ri (th6allowable' outage time-limits 6ýe defined6s the first tim'efrýmiie e66666ter-ed in r th6 -ACTION requir6merit)

S, -

3'

'24'h'ur'allowanc6.

shutdo,.ýh'isý required to -complywith ACTION rbiq-bire'ni6rit' e:g.,, Specification'.0.3, a

- o,

is proVided to permit a ýdeliy in lrolem 6nting the ACTION rdquir6m66t6:--This'provides inýcidEýqUlate time limit to'-cbm -plete'Surv'billinc6ý Requirements'tfi -at have not biieri'066ýd. The p6rpose"of this allow' ;arice is to permit the 66ýipletidh -of ai'ý&411an6e' b6f a shutdown is r6q&dd to comply with`ACtION requirem6hts or before btherr6medial measures4ould 'D-e'reýquir'e-a"that'fnaý,'ýr6clud6 ý&ýOletioh of a sLkve`iII66c6.,',' T6ý ba'sis'f6r thi's -6116wan6e'i'ncI6de's'consid e"ration-f Olaht'cdnditi6ni,ý6d66u'a-te'-p-lann'i-ng',',ý'

6vailýbility'df personnel,'the"-t!'r*p'e'-req'uire'-d't rf býj_ 4'eill6nGe; 'and thý s'afetj 6f 1:66 delay' in'ýcom-ple'ting thý_re6ulred sbrv6illakeý"This provision also providesa Z time imit or the"com pIetion'ý--"

ofSufvei[16-n"c'e'R'eq-u'ire-'m6nfi'tha-t'b'ec"o 'me ap"p'licable"as a__'c'66s6_quefi6e of MODIt 61ýaing6i:iriip6sed by-"!_

ACTION rbquiremenis'arfd f6r'c6niýletihgýSbiý6ilf6n'-c'e-Require-m-e6td-that ari6 bp'licýiblewh6n 6 n 6ý,66ptiýri to"the rie-qU-ire-rý6nts'cýfSpebýifiGation"-4.0.4is-'alloýv,ýd. -If'6'i6rveHLa6_c6'is not c'o'mpleted within the houi-,aillcwýric'e, thie'tim6 lin itsof the ACTION r-equ-ireim'e'nits' ard-apli'liclable ;itthat t1m6.,,,Wheri-.a sur *ýý 11 and th6_S6_ -&iIIanc6keq'uirements -ar, e, n, o I t I met veiý16n6iý is'performed Within the 24-hour a owance' rv the time Ifin-I& of th6 "ACTION iiýquiýement's-'a're"a"p"'p'li6ab]6'at -th6,ti -me that tfie'siurv6ifihc'elý t6nininkeý.-,--'

S men'is do nof have to'be performed on iii6perable*ýequipment e6aurveillan6e Require b

u e th6 ACTION".-`

,, e -,

rýq 'irbqferifs definie'th6're-m-6dial ineýS-L'ir6ý'th6t'6ý6iy."k6v;bv4r,:thýýSurv6illa'nc6'R'e'q"-uire m-66-ti have to,ý be met to-d6 nsti,ýie that ini5oer"abI6 6q_6ip"ment ha_ý be4ri-fest&6d t&OPERABIL-E 4 0.3 (Continued)

I Replace w/ ý

fl May 25, 2000 Amendment No. 69 SEQUOYAH - UNIT 2 B 3/4 0-4

ADMINISTRATIVE CONTROLS

b.

Air lock testing acceptance criteria are.

1)

Overall air lock leakage rate is < 0 05 La when tested at > Pa.

2)

For each door, leakage rate is < 0.01 La when pressurized to >_ 6 psig for at least two minutes.

The provisions of SR 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4.0 3 are applicable to the Containment Leakage Rate Testing Program.

i.

Configuration Risk Manaqement Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-informed allowed outage time has been granted. The program shall include the following elements:

a.

Provisions for the control and implementation of a Level 1 at-power internal events PRA informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b.

Provisions for performing an assessment prior to entering the Limiting Condition for Operation (LCO) Action for preplanned activities

c.

Provisions for performing an assessment after entering tne LCO Action for unplanned entry into the LCO Action.

d.

Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action.

e.

Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license or

2.

A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

Inserted new Section 6.8.j.

July 1, 1998 SEQUOYAH - UNIT 2 6-7 Amendment No. 34, 50, 66,134, 149, 169, 223

ADMINISTRATIVE CONTROLS d

Proposed changes that meet the criteria of Specification 6 8.j b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50 71(e).

6 9 REPORTING REQUIREMENTS Insert new Section 6.8 j.

ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4 STARTUP REPORT 6.9.1.1 DELETED 6.9.1.2 DELETED 6.9.1.3 DELETED SEQUOYAH - UNIT 2 January 14, 2002 Amendment No. 28, 50, 66, 134, 165, 261 6-7a

SQN 2 Technical Specification Change Inserts Insert I - TS 4.0.1 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Insert 2 - TS 4.0.3 4 0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.02), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

Insert 3 - Bases 4.0.1 4.0.1 SR 4 0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement. The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable. Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4.0.2, R1 constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b.

The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

E-7-8

SQN 2 Technical Specification Change Inserts - Continued Surveillances do not have to be performed when the unit is in a OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirement s associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be R1 completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

Insert 4 - Bases 4.0.3 4.0.3 SR 4 0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit 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 surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a surveillance 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 E-7-9

SQN 2 Technical Specification Change Inserts - Continued 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, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required AACTIONS.

Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval 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 If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins 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 entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed R1 Outage Time of the ACTIONS, restores compliance with Specification 4.0.1.

E-7-10

ENCLOSURE 12 (Revision 1)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SQN)

UNIT 1 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 REVISED PAGES AFFECTED PAGE LIST Page 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4 6-10b (New Page)

Adopt NUREG Adopt NUREG Adopt NUREG Adopt NUREG Adopt NUREG 1431 Rev 2 1431 Rev 2 1431 Rev 2 1431 Rev 2 1431 Rev 2 Wording & TSTF 358 Wording Wording Wording & TSTF 358 Wording II.

REVISED PAGES Attached E-1 2-1 (7 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3 Surveillances do not have to be performed on inoperable equipment or variables outside specified limits 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0 3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4 02), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0 5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be as follows.

Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports. The program shall include the following:

a Provisions that inservice testing of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;

b.

The provisions of SR 4.0 2 are applicable to the frequencies for performing inservice inspection activities; c

Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c 4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c.4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section XI; and

d.

Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS.

DATE SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. XXX

APPLICABILITY BASES instead, provided the other specified conditions are satisfied. In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCOs 3.0 1 and 3 0.2 (e g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate'

a.

The OPERABILITY of the equipment being returned to service, or b

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs.

This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

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

4 0.1 SR 4 0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable. Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4.0.2, constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances DATE SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No XXX

APPLICABILITY BASES Surveillances do not have to be performed when the unit is in a OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirement s associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

4.0.2 Specification 4 0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance, e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

4.0.3 SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit 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 surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval was not met.

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

DATE SEQUOYAH - UNIT 1 B 3/4 0-3a Amendment No. XXX

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

When a Surveillance with a surveillance 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, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4.0.3 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.

Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval 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.

If a Surveillance is riot completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins 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 entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the ACTIONS, restores compliance with Specification 4.0 1.

DATE SEQUOYAH - UNIT 1 B 3/4 0-4 Amendment No XXX

ADMINISTRATIVE CONTROLS Technical Specification (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following

1.

A change in the TS incorporated in the license or

2.

A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50 59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d.

Proposed changes that meet the criteria of Specification 5 5.14b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50 71(e).

DATE SEQUOYAH - UNIT 1 6-1Ob Amendment No XXXX

ENCLOSURE 13 (Revision 1)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SQN)

UNIT 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 REVISED PAGES AFFECTED PAGE LIST Page 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4 6-7 6-7a (New Page)

Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording & TSTF 358 Adopt NUREG 1431 Rev 2 Wording Adopt NUREG 1431 Rev 2 Wording II.

REVISED PAGES Attached E-13-1 (7 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0 1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0 3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4 0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.02), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered 4.0 4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports The program shall include the following.

a.

Provisions that inservice testing of ASME Code Class 1,2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;

b.

The provisions of SR 4 0 2 are applicable to the frequencies for performing inservice inspection activities; c

Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c 4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c 4.b(1) and c.4 b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10 year intervals coinciding with the Inservice Inspection schedule as required by ASME Section XI; and

d.

Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS.

DATE SEQUOYAH - UNIT 2 3/4 0-2 Amendment Nos. XXX

BASES 3.0.5 (Continued) specified conditions are satisfied. In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3 0.6 LCO 3.0 6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCOs 3.0.1 and 3.0.2 (e.g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate a

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs.

This Specification does not provide time to perform any other preventive or corrective maintenance An example of demonstrating the operability of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system 4.0.1 SR 4.0 1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement. The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4.0 2, constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

DATE SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No XXX

APPLICABILITY BASES Surveillances do not have to be performed when the unit is in a OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirement s associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0 2. Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing

b. High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

4.0.2 Specification 4.0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages The limitation of Specification 4 0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

4.0 3 SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit 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 surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4 0.2, and not at the time that the specified surveillance interval was not met.

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

DATE SEQUOYAH - UNIT 2 B 3/4 0-3a Amendment Nos. XXX

BASES 4.0.3 (Continued)

The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements When a Surveillance with a surveillance 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, Specification 4.0 3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4 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.

Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0 3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval 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.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins 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 entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the ACTIONS, restores compliance with Specification 4.0.1.

DATE SF01 IOYAH - IINIT 2 B 3/4 0-4 Amendment No. XXX V*

V 18 *Ol V.....

ADMINISTRATIVE CONTROLS b

Air lock testing acceptance criteria are:

1)

Overall air lock leakage rate is < 0 05 La when tested at _> Pa.

2)

For each door, leakage rate is _<

0.01 La when pressurized to > 6 psig for at least two minutes.

The provisions of SR 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4.0.3 are applicable to the Containment Leakage Rate Testing Program Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-informed allowed outage time has been granted The program shall include the following elements

a.

Provisions for the control and implementation of a Level 1 at-power internal events PRA informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b.

Provisions for performing an assessment prior to entering the Limiting Condition for Operation (LCO) Action for preplanned activities.

c Provisions for performing an assessment after entering the LCO Action for unplanned entry into the LCO Action.

d.

Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action.

e Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following

1. A change in the TS incorporated in the license or

2.

A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR DATE SEQUOYAH - UNIT 2 6-7 Amendment No. XXX,

ADMINISTRATIVE CONTROLS

d.

Proposed changes that meet the criteria of Specification 5.5 14b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

6 9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50 4.

STARTUP REPORT 6 9.1.1 DELETED 6.9.1 2 DELETED 6.9 1 3 DELETED DATE Amendment No. XXX, SEQUOYAH - UNIT 2 6-7a

ML022950112

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