Text

Application for Technical Specification Change Regarding Mode Change Limitations Using Consolidated Line Item Improvement Process
	ML032550036
Person / Time
Site:	Nine Mile Point
Issue date:	09/03/2003
From:	Katz P; Constellation Energy Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NMP2L 2099
	Download: ML032550036 (43)
	v • d • e

P.O. Box 63 Lycoming, New York 13093 Constellaton

-I-Energy Group Nine Mile Point Nuclear Station September 3, 2003 NMP2L 2099 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Nine Mile Point Unit 2 Docket No. 50-410- -

Application for Technical Specification Change Regarding Mode Change Lirmitations Using the Consolidated Line Item Improvement Process Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC, (NMPNS) is submitting a request for an amendment to the Nine Mile Point Unit 2 (NMP2) Operating License NPF-69. The proposed amendment would modify Technical Specifications (TS) requirements for ode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4.

Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant specific variations. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the existing TS Bases pages marked up to show the proposed change (for-information only). Attachment 4 provides a summary of the regulatory commitments made in this submittal.

NMPNS requests approval of the proposed license amendment by January 30, 2004, with an implementation period of sixty days.

In accordance with 10 CFR 50.91, a copy of this-application, with attachments, is being provided to the designated state representative.

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Page 2 NMP2L 2099 I declare under penalty of perjury that the foregoing is true and correct. Executed on September 3, 2003.

Sincere y, Peter E. Katz Vice President Nine Mile Point PEK/JJD/bjh Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-up)

3. Proposed Technical Specification Bases Changes (Mark-up)

4. List of Regulatory Commitments cc:

Mr. H. J. Miller, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR (2 copies)

Mr. John P. Spath, NYSERDA

ATTACHMENT 1 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify the Nine Mile Point Unit 2 (NMP2) Technical Specifications (TSs) requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4. The affected TSs and a summary of proposed changes are included in Table 1.

The changes are consistent with the NRC approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, "Increase Flexibility in MODE Restraints," TSTF-359, Rev. 9, dated April 25, 2003. TSTF-359, Rev. 9 is the equivalent of TSTF-359, Rev. 8, as modified by the notice in the FederalRegister dated April 4, 2003. That Federal Register notice announced the availability of this TS improvement through the consolidated line item improvement process (CLIP).

2.0 ASSESSMENT

2.1 Anylicabilitv of the Published Safety Evaluation Nine Mile Point Nuclear Station, LLC, (NMPNS) has reviewed the safety evaluation included in the Federal Register notice on April 4, 2003 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-359, Rev. 9. NMPNS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to NMP2 and justify this amendment for the incorporation of the changes to the NMP2 TSs.

2.2 Optional Changes and Variations NMPNS is not proposing any optional changes or deviations from the TS changes described in TSTF-359, Rev. 9 and the NRC staffs model safety evaluation included in the Federal Register notice on April 4, 2003.

However, due to minor differences between the NMP2 TSs and the model TSs in NUREG-1434, "Standard Technical Specifications, General Electric Plants, BWR/6,"

Rev. 2, several variances from the TSTF mark-up changes are necessary. These variations are discussed below and do not affect the adoption or application of TSTF-359, Rev. 9.

A.

TSTF-359 deletes the LCO 3.0.4 non-applicability note applying to all actions in Specification 3.4.7, "Reactor Coolant System." In the NMP2 TS, individual LCO Page 1 of 4

3.0.4 non-applicability notes are contained in the Required Actions for Conditions A and B. These notes are to be deleted.

B.

NMP2 does not have primary containment drywell hydrogen ignitors or a drywell purge system. Therefore, the proposed changes to the Specifications for theses systems identified in TSTF-359 are not applicable.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination NMPNS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLUP. NMPNS has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to NMP2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003 for this TS improvement, plant-specific verifications were performed as follows:

NMP2 has established TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to 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 TS Applicability.

Changes will be made to the bases for LCO 3.0.4 and SR 3.0.4 upon implementation of the proposed amendment that provide details on how to implement the new requirements.

The bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The bases changes describe in detail how:

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System Specific Activity), though it may be applied to other Specifications based on NRC plant-specific approval. The bases also state that any risk impact should be managed through the program in place to Page 2of 4

implement 10 CFR 50.65(aX4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. In addition, the bases state that upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. The bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

Finally, the NMP2 TSs have a bases control program consistent with Section 5.5 of the Standard Technical Specifications (STS), and the equivalent of STS SR 3.0.1 and associated bases.

4.0 Environmental Evaluation NMPNS has reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003 as part of the CLIIP. NMPNS has concluded that the staffs findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.

Page 3 of 4

TABLE 1 PROPOSED TECHNICAL SPECMCArTON (ITS) CHANGES Affected TS Descr ption of Change LCO 3.0.4 Addition of risk-informed evaluation of Mode changes SR 3.0.4 Clarification of relationship to SR 3.0.3 3.3.3.1 Post Accident Monitoring Deletion of Note exempting TS from LCO 3.0.4 Instrumentation 3.3.3.2 Remote Shutdown System Deletion of Note exempting TS from LCO 3.0.4 3.4.7 Reactor Coolant System Deletion of Note exempting Required Actions A. 1, (RCS) Leakage Detection B.1 and B.2 from LCO 3.0.4 Instrumentation 3.4.8 RCS Specific Activity Deletion of Note exempting Required Actions A. 1 and A.2 from LCO 3.0.4 Addition of Note stating applicability of LCO 3.0.4.c to Required Actions A. 1 and A.2 3.4.9 Residual Heat Removal Deletion of Note exempting TS from LCO 3.0.4 Shutdown Cooling System - Hot Shutdown 3.5.1 Emergency Core Cooling Addition of Note stating that LCO 3.0.4.b is not Systems (ECCS) - Operating applicable to the High Pressure Core Spray System

_CS) 3.5.3 Reactor Core Isolation Addition of Note stating that LCO 3.0.4.b is not Cooling (RCIC) System applicable to RCIC 3.6.3.1 Primary Containment Deletion of Note exempting Required Action A.1 Hydrogen Recombiners from LCO 3.0.4 3.8.1 AC Sources - Operating Addition of Note stating that LCO 3.0.4.b is not applicable to diesel generators (DGs)

Page 4 of 4

ATTACHMENT 2 PROPOSED TECHNICAL SPECMICATION CHANGES (MARK-UP)

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

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

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

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

Exceptions to this Specification are stated in the individual Specifications.

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

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

LCO 3.0.4 hen an ICO is at met, entry i a a MODE or o er specified condition in he Applicabilit shall not be m e except when the associ ed ACTIONS to be entered permit ontinued operatio in the MODE or o er specified c dition in the Applic ility for an unlP ited period of mie.

This Jin c>d1fe Spec icatian shall no prevent changes n MODES or at er speK fied conditions Xn the Applicabi Sty that are c ued (continued)

NMP2 3.0-1 Amendment 4H

e-1m -

LCO Applicability 3.0 3.0 LCO APPLICABILITY

/

LCO 3.0.4 (continued) xcep to this Spec-ation are ated in t e indivi al Specificati s.

LC

.0.4.is oni cable for n ry into a or ot er p

ity in S 1, 2, an LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not'required to be entered. Only the support system LCO ACTIONS'are required to be entered. This is an exception to LCO 3.0.2 for the supported system. 'In this event, an evaluation shall be performed in accordahce with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not

'(continued)

NMP2 3.0-2 Amendment -9+/-

SR Applicability 3.0 3.0 SR APPLICABILITY (continued)

SR 3.0.4 S

F V

t a

antry i ro a MOE or whe pecified condithon i parhe o

Pti w f heu t.

~ppic blity of an LCO sall-not be made unless'he LCO's

urvei'lances have been et within-their speci fed

'req Fcy. This proviso shall.not prevent ntry into IODE} or other specifid conditions in the Aplicability

hag are required to Xoply with-ACTIONS. o hat are part of hutdown of the unt/

3.0.4 is only plicable for entry i to a MODE or other

pecified conditi n in the Applicabili y in MODES 1, 2, and 3./

NMP2 3.0-5 Amendment PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 APPLICABILITY:

The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. -

MODES I and 2.

ACTIONS I_-NOTEf -----------------------------------

1.

030. snt

-iabe' Separate Condition entry is allowed for each Function.

______________________________________________________________________________- 19 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable.

status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6.

not met.

C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable.

status.

(continued)

NMP2 3.3.3. 1-1 Amendment -9i-

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 APPLICABILITY:

The Remote Shutdown System Functions shall be OPERABLE.

MODES 1Land 2.-

ACTIONS

/

\\ ---

NOTg -------------__

C 3.0.

Separate Condition entry is-allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME-A. One or more required A.1 Restore required 30 days Functions inoperable.

Function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

NMP2 3.3.3.2-1 Amendment.94-

ARCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain tank fill rate monitoring system; and

b. One channel of either drywell atmospheric particulate or atmospheric gaseous monitoring system.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain

--NOTE-----

tank fill rate L 0 3.

is not ap icable.

monitoring system inoperable.

A.1 Restore drywell floor 30 days drain tank fill rate monitoring system to OPERABLE status.

B. Required drywell NOTE---

atmospheric monitoring ICO 3.4 is not app c system inoperable.

B.1 Analyze grab samples Once per of drywell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere.

AND..

B.2 Restore required 30 days drywell atmospheric monitoring system to OPERABLE status.

1 (continued)

NMP2 3.4.7-1 Amendment 4i-

RCS Specific Activity 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Specific Activity LCO 3.4.8 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity S 0.2 ACi/gm.

APPLICABILITY:

MODE 1, MODES 2 and 3 with any main steam line not isolated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.. Reactor coolant

-NOTE-----

specific activity LCO 3.0.4 isc= applicable.

> 0.2 pCi/gm and S 4.0 pCi/gm DOSE EQUIVALENT 1-131.

A.1 Determine DOSE Once per.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT 1-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limits.

8. Required Action and B.1 Determine DOSE

-Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion EQUIVALENT 1-131.

Time of Condition A not met.

AND OR B.2.1 Isolate all main 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months steam lines.

Reactor coolant Specific activity OR

> 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued)

I NMP2 3.4.8-1 Amendment -04

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES---------------------------

1. -Both RHR shutdown cooling subsystems and recirculation pumps may be not in operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY:

MODE 3 with reactor steam dome pressure less than the RHR cut-in permissive pressure.

ACTIONS q/Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable.

cooling subsystem to OPERABLE status.

AND (continued)

NMP2 3.4.9-1 Amendment -f+

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 APPLICABILITY:

Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig.

ACTIONSe AK 5 ', 3 CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable.

subsystem to OPERABLE status.

B. High Pressure Core B.1 Verify by Immediately Spray (HPCS) System administrative means inoperable.

RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System 14 days to OPERABLE status.

(continued)

I NMP2 3.5. 1-1 Amendment OK4-

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 APPLICABILITY:

The RCIC System shall be OPERABLE.

MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS&-

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable.

administrative means High Pressure Core Spray System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

-associated Completion Time not met.

AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

< 150 psig.

I NMP2 3.5.3-1 Amendment 94-

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners LCO 3.6.3.1 Two primary OPERABLE.

containment hydrogen recombiners shall be APPLICABILITY:

MODES I and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One primary'-

A.1 containment hydrogen LCO 3.4 is not recombiner inoperable.

app cable.

Restore primary 30 days containment hydrogen recombiner to OPERABLE status.

B. Two primary B.1 Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months containment hydrogen administrative means recombiners that the hydrogen and AND inoperable.

oxygen control function is Once per maintained.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status.

(continued)

NMP2 3.6.3.1-1 Amendment -9+

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class lE AC Electric Power

-Distribution System; and

b. Three diesel generators (DGs).

APPLICABILITY:

MODES 1, 2, and 3.

7-------NOTE----------------------------

Division 3 AC electrical power sources-are not required to be OPERABLE when High Pressure Core Spray (HPCS) System is inoperable.

ACTIONS&--

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable.

for OPERABLE required offsite circuit.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND (continued)

I NMP2 3.8. 1-1 Amendment -9+

Insert 1 (LCO 3.0.4)

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

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c.

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

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

Insert 2 (SR 3.0.4)

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

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

Insert 3 (LCO 3.5.1)

NOTE ---.

LCO 3.0.4.b is not applicable to HPCS.

Insert 4 (LCO 3.5.3)

NOTE O

-E-------------

LCO 3.0.4.b is not applicable to RCIC.

Insert 5 (LCO 3.8.1)

NOTE ---------

LCO 3.0.4.b is not applicable to DGs.

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

The mark-up Bases pages are provided for information only.

LCO Applicability B 3.0 1

BASES LCO 3.0.3 assemblies in the spent fuel storage pool."

Therefore, this (continued)

LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.6 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition.

The Required Action of LCO 3.7.6 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the LCO 3.0.4

.is e

1 14UI V I %

Q I

II act-lit v

UII.

ICO 3.0.4 establishes imitations on change in MODE o other specified con tions in the Applicab ity when an LCO is not met. It pr ludes placing the uni in a MODE or other specified c dition stated in that Applicability (e.g., Applicabi ty desired to be ent ed) when the following exist/

a.

Unit con tibns are such that e requirements of the LCO wout not be met in the A licability desired to be ent ed; and

b. Cont' ued noncompliance wi the LCO requirements, if the Applicability were en ered, would result in the unt being required to e it the Applicability desired t be entered to comply ith the Required Actions.

Comp iance with Required A ions that permit continued op ation of the unit for n unlimited period of time n a M E or other specified ondition provides an accepta e vel of safety for continued operation. This is wi hout egard to the status o the unit before or after th MODE change. Therefore, such cases, entry into a MO or other specified con;tion in the Applicability ma be made in accordance with he provisions of the Require Actions.

The provisions of this Specification should not e interpreted as dorsing the failure to exerci the good practice of re oring systems or components t OPERABLE status befor entering an associated MODE or ther specified condition i the Applicability.

(continued)

NMP2 B 3.0-5 Revision -&

LCO Applicability B 3.0 BASES LCO 3.0.4 The provisions of L 3.0.4 shall not prevent change in (continued)

MODES or other spe fled conditions in the Applica ity that are required to comply with ACTIONS.

In ad ion, the provisions of LC 3.0.4 shall not prevent chan in MODES or other specif ed conditions in the Applicab ity that result from a unit shutdown.

Exceptions a LCO 3.0.4 are stated in th individual Specifica ons.

The exceptions allow try into MODES or other sp cified conditions in the App cability when the associ ed ACTIONS to be entered do ot provide for conti ed operation for an unlimitd period of time.

Exc tions may apply to all the TIONS or to a specific Re ired Action of a Specifica on.

urveillances do not have t be performed on the associate inoperable equipment (or a variables outside the specifi limits), as permitted by R 3.0.1. Therefore, changing MODES or other specifi conditions while in an ACTIO Condition, either in ompliance with LCO 3.0.4, or w re an exception to LCO 3..4 is stated, is not a violati of SR 3.0.1 or SR 3..4 for those Surveillances tha do not have to be perfored due to the associated inop able equipment. Ho ver, SRs must be met to ensur OPERABILITY prior to dec ring the associated equipment ERABLE (or variable wi in limits) and restoring compl ance with the affected 0.

LCO 3..4 is only applicable when enter ng MODE 3 from MODE

, MODE 2 from MODE 3 or 4, or M E 1 from MODE 2.

Fur ermore, LCO 3.0.4 is applicabl when-entering any other s cified condition in the Applica lity only while perating in MODE 1, 2, or 3. T requirements of LCO 3.0.4 do not apply in MODES 4 and 5, r in other specified conditions of the Applicabili (unless in MODE 1, 2, or 3) because the ACTIONS of indi dual Specifications Sufficiently define the re edial measures to be taken.

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

(continued )

NMP2 B 3.0-6 Revision 4-

SR Applicability B 3.0 a;

BASES SR 3.0.3 (continued) and rigor of the evaluation should be commensurate with the importance 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 Corrective Action Program.

Of If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable then 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 t e requirement that all applicole SRs must be met before entry into a M,DE or other specified condi n in the Applicability.

This Specification nsures that system and co ponent OPERABILITY requirements an ariable limits are met bef e entry into MODES or other specified nditions in the Applicabili for which these systems and components erure safe operation of the nit The provisio s of this Specification sh uld not be interpreted as endorsing e failure to exercise the ood practice of restoring systems or componen to OPERABLE statusyefore entering an associated MODE or other specified conditon in the pplicability.

V,,,(r'^-'

Howev in certain circumsta es, failing to meet an SR will not res in SR 3..4 restricting a MODE ange or other specified condition nge.

Whe a system, subsyste

,division, component, device, or variade is Iop rable or outside its ecified limits, the associated SR(s) ar not req ired to be performe per SR 3.0.1 which states that Surveil nces do not have to be perforrd on inoperable equipment. When e uIpment is inoperable, SR 3.0.4 oes not apply to the associated SR(s) ince the requirement for the R(s) to be performed is removed. Th efore, failing to perform the S eillance(s) within the specified Freque y, on equipment that' inoperable, does not result in an SR 3.4 restriction to changing MOVES or other specified conditions of Vie Appl(cability.

However, sin~ te LCO is not met in this instance, LCO3.0.4 will govern

~~~~~~~~~~~~~~~~C NMP2 B 3.0-15 Revision 0, e-(A elf-

SR Applicability B 3.0 BASES SR 3.0.4 (continued) aorestrictions Ula1 may or y not) apply {to-MIODE or other sp y condition changes.

The provisions of SR 3.94 shall not prevent changes in ODES or other specified conditions in e Applicability that are require to comply with ACTIONS. In additio

,the provisions of SR 3.0.4 sh 1 not prevent changes in MODES r other specified conditions in e Applicability that result from any unit hutdown.

The precise req ements for performance of S s are specified such that exceptions to S 3.0.4 are not necessary. Th specific time frames and conditions ne ssary for meeting the SRs ar specified in the Frequency, in the Survei nce, or both. This allows perormance of Surveillances when the p requisite condition(s) specifie in a Surveillance procedure require e Into the MODE or other spe ified condition in the -

Applicab ity of the associated LCO prio to the performance or completion of a Su eillance. A Surveillance that uld not be performed until after enteri the LCO Applicability would ave its Frequency specified such that its not "due" until the specific nditions needed are met.

Alte tely, the Surveillance may stated in the form of a Note as n req ired (to be met or performed rntil a particular event, condition, r ti has been reached. Furthe discussion of the specific formats f SRs' notation is found in Section

-4, Frequency.

SR 3.0.4 is only applicable en entering MODE 3 from MODE4, MODE 2 from MODE 3 or 4, or M DE 1 from MODE 2. Furthermnore R 3.0.4 is applicable when entering ny other specified condition in the pplicability only while operating in ODE 1, 2, or 3. The requirements f SR 3.0.4 do not apply in MODE 4 and 5, or in other specified con tions of the Applicability (unless i MODE 1, 2, or 3) because the A IONS of individual SpecificaU ns sufficiently define the remedial easures to be NMP2 B 3.0-16 Revision 0, _ (,4 87-

PAM Instrumentation E 3.3.3.1 BASES LCO

11.

Suppression Pool Water Temperature (continued) available for the indicator and a different pen recorder for each sensor is available for the two recorders so that each sensor can be monitored. The indicator and recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels.

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2.

These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES l'and 2. In MODES 3, 4, and 5,

-plant conditions are such that the likelihood-of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS Note 1 has een added to the ACT S to exclude the MOUDE change r triction of LCO 3.0..

This exception allows entry i o the applicable MOD while relying on the ACT NS even t ough the ACTIONS may ventually require plant shutd n. This exception acceptable due to the ssive fun ion of the instrumen s, the operator's abili to di nose an accident us' g alternate instruments nd ftods, and the low poability of an event r urngths nstruments.z A Note has

-been provided to modify the ACTIONS related to PAM instrumentation channels-. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate inoperable functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function.

(continued)

NMP2 B 3.3.3.1-8 Revision +

Remote Shutdown System

- B 3.3.3.2 BASES APPLICABILITY (continued) necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the LCO does not require OPERABILITY in MODES 3, 4, and 5.

ACTIONS A Note is in ded that excludes e MODE change restr ton of LCO 3.0v(

This exception a sws entry into an/)

applicabl MODE while relying n the ACTIONS even ough the ACIN0 fa eventually requit a plant shutdown.,tis

/

xcepon is acceptable du to the low probabil y of an e

uiigtis Syst of A Note has been provided to modify the ACTIONS related to Remote Shutdown System Functions.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Act-ions of-the-Condition-continue to-apply f6reach additional failure, with Completion Times based on initial entry into the Condition.

However, the Required Actions for inoperable Remote Shutdown System Functions prov-ide appropriate compensatory measures for separate Functions.

As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function.

A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System is inoperable. This includes any Function listed in Reference 4, as well as the control and transfer switches.

The Required Action is to restore the Function (both divisions, if applicable) to OPERABLE status within 30 days.

The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

B.1 If the Required Action and associated Completion Time of Condition A are not met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, (continued)

NMP2 B 3.3.3.2-3 Revision-0.

RCS Leakage Detection Instrumentation B 3.4.7 BASES (continued)

LCO The drywell floor drain tank fill rate monitoring system is required to quantify the unidentified LEAKAGE from the RCS.

The other monitoring system (particulate or gaseous) provides early alarms to the operators so closer examination

-of other detection systems-will be made to determine the -

extent of any corrective action that may be required. With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded.

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems/are required to be OPERABLE to support LCO 3.4.5. This Applicability is consistent with that for LCO 3.4.5.

ACTIONS

.I With the drywell floor drain tank fill rate monitoring system inoperable, no other form of sampling'can provide the equivalent information to quantify leakage.

However, the drywell atmospheric activity monitor will provide indications of changes in leakage.

With the drywell floor drain tank fill rate monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (SR 3.4.5.1),

operation may continue for 30 days.

The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of moniog eC leon that are still availableg

-ction A.1 ien No,, that states that t iprhvisio f LeCo a30.4 are t applicable. As ap esult, a MODE cinge iscanllowed wherta e drywell fltor dr yl tank atmosherc monitoring system is inoperable.

Tho allowancel leakage inforcatse on instrumentation is tained1and monitor RCS lea(oge.nie' B.1 and B.2 With both gaseous and particulate drywell atmospheric monitoring channels inoperable (i.e., the required drywell atmospheric monitoring system), grab samples of the drywell atmosphere shall be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and (continued)

NMP2 8 3.4.7-3 Revision.0-

RCS Leakage Detection Instrumentation B 3.4.7 BASES ACTIONS B.1 and 6.2 (continued) analyzed every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of at least one of the required monitors.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

e equir ctions are modifi by a Note that st s at the prov ions of LCO 3.0.4 a not applicable.

a result aMODE change is al wed when both the eous and parti ulate primary conta' ment atmospheric mo toring ch nfels are inoperable This allowance is ovided bec se C.1 and C.2 If any Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions in an orderly manner and without challenging plant systems.

D.-

With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is-required.

SURVEILLANCE The Surveillances are modified by a Note to indicate that REQUIREMENTS when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , provided the other required instrumentation (either the drywell floor drain tank fill rate monitoring system or the drywell atmospheric monitoring channel, as applicable) is OPERABLE. Upon completion of the Surveillance, or (continued)

NMP2 B 3.4.7-4 Revision --

RCS Specific Activity B 3.4.8 BASES APPLICABLE The limit on specific activity is a value from a SAFETY ANALYSES parametric evaluation of typical site locations. This limit (continued) is conservative because the evaluation considered more restrictive parameters than for a specific site, such as the location of the site boundary and the meteorological conditions of the site.

RCS specific activity satisfies Criterion 2 of Reference 3.

LCO The specific iodine activity is limited to < 0.2 gCi/gm DOSE EQUIVALENT 1-131.

This limit ensures the source term

-assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 100 limits.

APPLICABILITY In MODE 1, and MODES-2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment.

In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced.

ACTIONS A.1 and A.2

.When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT 1-131 limit, but is < 4.0 iCi/gm, samples must be analyzed for DOSE EQUIVALENT I-131 at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In addition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to take and analyze a sample.

The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems.

A Note to He Required ActionoT Condition A ex udes the MODE chape restriction of 0 3.0.4. This e eption allows entry to the applicable ODE(S) while rel Ing onthe

--P-5 or I Wq.

.. I.-

F NMP2 B 3..4.8-2 Revision 4

RCS Specific Activity B 3.4.8 BASES ACTIONS A.1 and A.2 (continued)

\\shwtdtzi-wZ~his ionts acceptable o eJ significant conservatism incorporated Into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient speqific activity excursions while the plant remains at, or proceeds to power operation.

B.1. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to

< 0.2 pCi/gm within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if at any time it is

> 4.0 ICi/gm, it must be determined at least every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and all the main steam lines must be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in-an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident.

Alternately, the plant can be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads).

In MODE 4, the requirements of the LCO are no longer applicable.

The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the time needed to take and analyze a sample.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems.

Also, the allowed Completion Times for Required Actions B.-2.2.1 and 8.2.2.2 for bringing the plant to MODES 3 and 4 are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

NMP2 8 3.4.8-3 Revision4

k I RHR Shutdown Cooling System-Hot Shutdown B 3.4.9 BASES (continued)

ACTIONS A ote to he ACTIONS excludes e MODE change rest ction of LCO 3.4.- This exceptlo allows entry into t applic le MODE while rely Og on the ACTIONS eve though the ACTIO may eventual-ly-re uire plant shutdown. This exc tion is acceptable ue to the redundancy/of the A

LE subsystems, e low pressure at w the plant is oeaing, the low pf~ability of an even/curring drn

\\ Oeraio inths pfidition, and the avai bility of t tenat mehodzofdecay heat remova caability A 4gaaffiR)Note has been provided to modify the ACTIONS related to KIIK-snutuown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems.

As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.I. A.2. and A.3 With one RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay.

In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal.

The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown cooling subsystem inoperability.

This re-establishes backup decay heat removal capabilities, similar to the requirements of the LCO. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the decay heat removal function and the probability of a loss of the available decay heat removal capabilities.

(continued)

NMP2 8 3.4.9-3 Revision.

! -.

oj 1 ECCS-Operating B 3.5.1 BASES (continued)

I ACTIONS j3s &

ff 5*f If any one low pressure ECCS injection/spray subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days.

In this condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA.

However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a LOCA may result in the ECCS not being able to perform its intended safety function.

The 7 day-.Completion Time is based on a reliability study (Ref. 13) that evaluated the impact on ECCS availability by assuming that various components and subsystems were taken out of service.

The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.1 and B.2 If the HPCS System is inoperable, and the RCIC System is immediately verified to be OPERABLE (when RCIC is required to be OPERABLE), the HPCS System must be restored to OPERABLE status within 14 days. In this condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with the ADS.

Also, the RCIC System will automatically provide makeup water at most reactor operating pressures.

Immediate verification of RCIC OPERABILITY is therefore required when HPCS is inoperable and RCIC is required to be OPERABLE. This may be performed by an administrative check, by examining logs or other information, to determine if RCIC is out of service for maintenance or other reasons. It is not necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System.

However, if the OPERABILITY of the RCIC System cannot be immediately verified and RCIC is required to be OPERABLE, Condition D must be entered.

If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is based on the results of a reliability study (Ref. 13) and has been found to be acceptable through operating experience.

(eontinuedl NMP2 B 3.5.1-6 Revision RCIC System B 3.5.3 BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, (continued) which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge line "keep fill' system is designed to maintain the pump discharge line filled with water.

APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation.

Based on its contribution to the reduction of overall plant risk, the system satisfies Criterion 4 of

.Reference 3.

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity to maintain RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE in MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure 5 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the ECCS injection/spray subsystems can provide sufficient flow to the vessel.

ACTIONS A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODES 2 p-5-e-5 or 3 with reactor steam dome pressure > 150 psig, and the

,r 4cS

/HPCS System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days.

(continued)

I NMP2 B 3.5.3-2 Revision Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES ACTIONS L.1 (continued) accumulation exceeding this limit, and the low probability of failure of the OPERABLE primary containment hydrogen recombiner.

equired Ac on A.1 has been mo ied by a Note stat g that the provis'ons of LCO 3.0.4 ar not applicable.

As/a

result, MODE change is allo ed when one recombinr is inopera e. This allowance s provided because t the low probab lity of the occurre ce of a LOCA that world generate 8.1 and 8.2 With two primary containment hydrogen recombiners inoperable, the ability to perform the hydrogen and oxygen control function via an alternate capability must be verified by administrative means within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen andoxygen control capability is provided by the Primary Containment Vent, Purge, and-Nitrogen System' and one RHR drywell spray subsystem. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time allows a reasonable period of time to verify that a loss of hydrogen and oxygen control function does not exist.

In addition, the alternate hydrogen and oxygen control system capability must be verified once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter to ensure its continued availability.

Both the initial verification land all subsequent verifications may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen and oxygen control system. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the alternate hydrogen and oxygen control system. If the ability to perform the hydrogen and oxygen control function is maintained, continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Seven days is a reasonable time to allow two hydrogen recombiners to be inoperable because the hydrogen and oxygen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in the amounts capable of exceeding the flammability limits.

(continuedi NMP2 B 3.6.3.1-4 Revision AC Sources-Operating B 3.8.1 BASES LCO operating in parallel test mode.

Proper sequencing of (continued) loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

The AC sources in one division must be separate and independent (to the extent possible) of the AC sources in the other division(s). For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical.

APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not'exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

A Note has been added taking exception to the Applicability requirements for Division 3 sources, provided the HPCS

-System is declared inoperable.

This exception is intended to allow declaring of the Division 3 inoperable either in lieu of declaring the Division 3 source inoperable, or at any time subsequent to entering ACTIONS for an inoperable Division 3 source. This exception is acceptable since, with the Division 3 inoperable and the associated ACTIONS entered, the Division 3 AC sources provide no additional assurance of meeting the above criteria.

AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in -

LCO 3.8.2, 'AC Sources-Shutdown."

ACTIONS A.1 To ensure a highly reliable power-source remains, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis.

Since the Required Action only specifies 'perform,' a failure of SR 3.8.1.1 acceptance criteria does not result in the Required Action not met. However, if the second required (continued)

I NMP2 B 3.8.1-5 Revision Bases Insert 1 (LCO 3.0.4 Bases) 1 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

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

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

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(aX4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

Bases Insert 1 (cont.)

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable.

NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

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

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

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

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

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

Bases Insert 1 (cont.)

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

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

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

Bases Insert 2 (SR 3.0.4 Bases)

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.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

Bases Insert 2 (cont.)

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. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

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

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

Bases Insert 3 (RCS Specific Activity Bases)

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

Bases Insert 4 (ECCS - Operating Bases)

A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCS subsystem.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCS subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Bases Insert 5 (RCIC System Bases)

A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Bases Insert 6 (AC Sources - Operating Bases)

ANote prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by NMPNS in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Regulatory Commitment Due Date/Event NMPNS will establish the TS Bases as j Upon implementation of the amendment.

adopted with the license amendment.

I

v t e Letter Sequence Request
TAC:MC0623, (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other: ML040060295
MONTHYEAR2003-09-03 [Table View]

ML032550036

Text

SUBJECT:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

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