ML060600360
| ML060600360 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/06/2006 |
| From: | Pace P Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TVA-SQN-TS-05-08 | |
| Download: ML060600360 (16) | |
Text
- V Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 February 6, 2006 TVA-SQN-TS-05-08 10 CFR 50.90 U.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 SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 -
TECHNICAL SPECIFICATIONS (TS)
CHANGE: 05-08, "APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LIMITING CONDITION FOR OPERATION 3.0.7 ON THE INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)"
Pursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting a request for a TS change (TS 05-08) d:o Licenses DPR-77 and DPR-79 for SQN Units 1 and 2.
The proposed amendment would modify TS requirements for inoperable snubbers by adding LCO 3.0.7. provides a description of the proposed change, the requested confirmation of applicability, and plant specific verifications. provides the existing TS pages marked-up to show the proposed change.
provides a summary of the regulatory commitments made in this submittal. provides the existing TS Bases pages marked up to show the proposed change (for information only).
Pinted on recyded paper
U.S. Nuclear Regulatory Commission Page 2 February 6, 2006 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.
There is no specific timeframe in which the licensee needs this change and therefore, normal NRC processing is requested.
TVA requests that the implementation of the revised TS be within 45 days of NRC approval.
If you have any questions about this change, please contact me at 843-7170 or Jim Smith at 843-6672.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 6th day of February, 2006.
Sincerely, P. L. Pace Manager, Site Licensing and Industry Affairs
Enclosures:
- 1. TVA Evaluation of the Proposed Changes
- 2. Proposed Technical Specifications Changes (mark-up)
- 4. Proposed Technical Specification Bases Changes cc:
See page 3
U.S. Nuclear Regulatory Commission Page 3 February 6, 2006 Enclosures cc (Enclosures):
Framatome ANP, Inc.
P. 0. Box 10935 Lynchburg, Virginia 24506-0935 ATTN:
Mr. Frank Masseth Mr. Lawrence E. Nanney, Director Division of Radiological Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 Mr. Douglas V. Pickett, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY (TVA)
SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 Description and Assessment
1.0 DESCRIPTION
The proposed amendment would modify technical specifications (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.7.
The changes are consistent: with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) standard TS change TSTF-372, Revision 4.
The availability of this TS improvement was published in the Federal Register on May 4, 2005, as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation TVA has reviewed the safety evaluation dated May 4, 2005, as part of the CLIIP.
This review included a review of the NRC staff's evaluation, as we-l as the supporting information provided to support TSTF-372. TVA has concluded that the justifications presented In the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to SQN Units 1 and 2 and justify this amendment for the incorporation of the changes to the SQN TSs.
2.2 Optional Changes and Variations TVA is not proposing any variations or deviations from the TS changes described in the TSTF-372, Revision 4 or the NRC staff's model safety evaluation dated May 4, 2005.
The only difference from the model is a numbering difference for the new LCO 3.0.7 in place of the TSTF-372 proposed LCO 3.0.8.
This difference is because SQN has not incorporated the current LCO 3.0.7 found in the latest version of standard TS (NUREG-1431).
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination TVA has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. TVA has concluded taat the El-l
proposed NSHCD presented in the Federal Register no:ice is applicable to SQN 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 May 4, 2005 for this TS improvement, plant-specific verifications were performed as follows:
TVA will establish TS Bases for LCO 3.0.7, which provide guidance and details on how to implement the new requirements.
LCO 3.0.7 requires that risk be managed and assessed.
The Bases also state that while the industry and NRC guidance on implementation of 10 CFR 50.65(a)( 4 K, the Maintenance Rule, does not address seismic risk, LCO 3.0.7 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed.
The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
Finally, SQN has a Bases Control Program consistent with Section 5.5 of the STS.
4.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005, as part of the CLIIP.
TVA has concluded that the staff's findings presented in that evaluation are applicable to SQN and the evaluation is hereby incorporated by reference for this application.
E1-2
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS' 1 AND 2 Proposed Technical Specification Changes (mark-up)
I.
AFFECTED PAGE LIST Unit 1 Unit 2 3/4 0-1 3/4 0-2 3/4 0-1 3/4 0-2 II.
MARKED PAGES See attached.
E2 -1
INSERT I 3.0.7 When one or more required snubbers are unable to perf3rm their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:
- a.
the snubbers not able to perform their associated support function(s,) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
- b.
the snubbers not able to perform their associated support function(s,) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affectedd supported system LCO(s) shall be declared not met.
E2-2
3/4 LIMITING CONDITIONS FOR OPEATION AN1D SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY andasprovide~dinLCO3.0.7 LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Speci tions is required during the OPERATIONAL MODES or other conditions specified therein; except tha upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements sha berme.
3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time interva s, completion of the ACTION requirements is not required.
3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:
- 1.
At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
- 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
- 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated n the individual Specifications.
3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a.
When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
- b.
After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
- c.
When an allowance is stated in the individual value, parameter, or other Specification.
This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:
- 1.
At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
- 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
- 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This Specification is not applicable in MODES 5 or 6.
April 11, 2005 SEQUOYAH - UNIT 1 3/4 0-1 Amendment No. 202, 301 E2-3
APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 3.0.6 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 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstr e OP 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 surveillarce interval (including the allowed extension per Specificatior 4.0.2), 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 te entered.
4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall orly be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. 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.C0.4.
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.
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:
April 11, 2005 SEQUOYAH - UNIT 1
.3/4 0-2 Amendment No. 78, 162, 202, 208, 274, 280, 293, 301 E2-4
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY vcied in LCO 3.0.7 LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Spi S
is required during the OPERATIONAL MODES or other conditions specified therein; except that up n failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall b met.
3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition or Operation and associated ACTION requirements are not met within the specified time inter/als. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.
3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:
- 1.
At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,
- 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
- 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.
3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a.
When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
- b.
After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
- c.
When an allowance is stated in the individual value, parameter, or other Specification.
This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that: are part of a shutdown of the unit.
3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant: system(s), subsystem(s), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:
- 1.
At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
- 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
- 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This Specification is not applicable in MODES 5 or 6.
April 11, 2005 SEQUOYAH - UNIT 2 3/4 0-1 Amendment No. 192, 290 E2 -5
APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.6 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 3.0.1 and 3.0.2 for the system returned to service under administrative ontrol to perform the testing required to demonstrate OPERABAIBa 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 4.0.2), 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 a MODE or other specified condition in the Applicability of an LCO shall orly be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. 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.
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:
April 11, 2005 SEQUOYAH - UNIT 2
,3/4 0-2 Amendment No. 69, 152, 198, 263, 271, 283, 290 E2-6
ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY (TVA)
SEQUOYAH NUCLEAR PLANT (SQN)
UNITS' 1 AND 2 List of Regulatory Commitments The following table identifies those actions committed to by TVA in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Please direct questions regarding these commitments to Paul Pace.
REGULATORY COMMITMENTJS DUE DATE/EVENT TVA will establish the Technical To be implemented Specification Bases for LCO 3.0.7 as with the Technical adopted with the applicable license Specification amendment.
amendment.
E3-1
ENCLOSURE 4 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNIT'S 1 AND 2 Changes to Technical Specifications Bases Pages I.
AFFECTED PAGE LIST Unit 1 Unit 2 B 3/4 0-3 B 3/4 0-3 II.
MARKED PAGES See attached.
E4-1
INSERT 2 3.0.7 LCO 3.0.7 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considerei to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s),
the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.1.
LCO 3.0.7.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.7,a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72-hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
LCO 3.0.7.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.7.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12-hour Completion Time is reasonable based or the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.
LCO 3.0.7 requires that risk be assessed and maiaged. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.7 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated suppDrt function.
E4-2
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 tfu eaespo rformance of an SR on another channel I the same trip system.
4 1
Insert2
)
4.0.1 SR 4.0.1 establishes remethat survei nces must be me r
t ERATIONAL MODES or other specified conditions in e App =W forements of 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 a 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.
February 5, 2003 SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78, 162, 202, 280 E4 -3
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 ction and dite the app ropria e performance of an SR on another channel n the same rip systeeii I
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4.0.1 SR 4.0.1 establishes ih hee t
ERATIONAL MODES or other specified conditions in the Applicability for which the requirements of 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 a 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 February 5, 2003 SEQUOYAH - UNIT 2 13 3/4 0-3 Amendment No. 69, 152, 192, 271 E4 -4