GO2-06-060, Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers (TSTF-372) Using the Consolidated Line Item Improvement Process

Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers (TSTF-372) Using the Consolidated Line Item Improvement Process

ML061110138
Person / Time
Site:	Columbia
Issue date:	04/17/2006
From:	Oxenford W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-06-060, LCO 3.0.8, TATF-372
Download: ML061110138 (17)

Text

ENERGY NJ NORTHWEST People Vision Solutions P.O. Box 968 Richland, WA

• 9935:2-0968 April 1.7, 2006 G02-06-060 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90, Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia). The proposed amendment would modify TS requirements for inoperable snubbers by adding LCO 3.0.8. provides a evaluation of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show the proposed change (for information only).

Energy Northwest requests approval of the proposed License Amendment by August 30, 2006, with the amendment being implemented within 60 days.

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

4co(/

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, WS Oxen r Vice President, Technical Services Mail Drop PE04 Attachments:

1. Evaluation of the Proposed Change

2.

Proposed Technical Specifications Changes (mark-up)

3.

Proposed Technical Specifications Pages (retyped)

4.

Summary of the Regulatory Commitments

5.

Proposed Technical Specifications Bases Changes (mark-up) cc: BS Mallett - NRC RIV BJ Benney-NRC NRR TH Boyce - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn JO Luce - EFSEC RR Cowley - WDOH

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 O1 THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Page 1 of 2 Evaluation of the Proposed Change

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding LCO 3.0.8. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS 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 Energy Northwest has reviewed the safety evaluation dated November 24, 2004 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-372. Energy Northwest has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Columbia and justify this amendment for the incorporation of the changes to the Columbia TS.

2.2 Optional Changes and Variations Energy Northwest is not proposing any variations or deviations from the TS changes described in TSTF-372 Revision 4 or the NRC staffs model safety evaluation dated Novernber 24, 2004. However, Energy Northwest currently has a Licensee Controlled Specification (LCS) 1.7.3 that addresses Snubber operability requirements and required compensatory measures. LCS 1.7.3 will be revised to reference TS LCO 3.0.8 during the implementation of the approved amendment.

3.0 REGULATORY ANALYSIS

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

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Attachment I Page 2' of 2 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:

Energy Northwest has established TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements (see attachment 5). LCO 3.0.8 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), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 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.

The LCO 3.0.8 Bases will be incorporated into the TS Bases during the implementation of the approved amendment in accordance with the existing TS Bases Control Program (reference TS 5.5.10).

4.0 ENVIRONMENTAL EVALUATION Energy Northwest has reviewed the environmental evaluation included in the model safety evaluation dated November 24, 2004 as part of the CLIIP. Energy Northwest has concluded that the staffs findings presented in that evaluation are applicable to Columbia and the evaluation is hereby incorporated by reference for this application.

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 OIN THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LIINE ITEM IMPROVEMENT PROCESS Proposed Technical Specifications Changes (mark-up)

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO

.0.1 LCOs shall be met during the MODES or other specified conditions in Ahe Applicabil ed in LCO 3.0 L

CO 3.0.7.

4f.z LCO

',.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 2.0.3 When an LCO is not met and the associated ACTIONS are no,:

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

a. MODE 2 within 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />s:

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

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

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 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; (continied)

Columbia Generating Station 3.0-1 Amendment No.

149,169 187

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

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 desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

\\ ICO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be 1

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 functlon(s), or the affected supported system LCO(s) shall be declared not met.

Columbia Generating Station 3.0 -3 Amendment No. 149,169 180l

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LI1NE ITEM IMPROVEMENT PROCESS Proposed Technical Specifications Pages (retyped)

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO ^.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

LCO 2.0.2 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 otherw'se stated.

LCO 2.0.3 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

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

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

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

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 2.0.4 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; (continued)

I Columbia Generating Station

3. 0-1 Amendment No.

149,169,-143-
'

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO

.0.4 (cortinued)

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.

LCO

$.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

"..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, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)."

If a loss of safety func7:ion 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 suppor:ed system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, -he applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Columbia Generating Station

3.

0- 2 Amendment No.

149,169 187

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

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 desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

LCO 3.0.8 When one or more required snubbers are unable to perform 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 affected supported system LCO(s) shall be declared not met.

Columbia Generating Station

3. 0- 3 Amendment No.

149,169 4-8-D

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

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

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

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, 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 Frequency, 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 LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Columtia Generating Station 3.0 -4 Amendment No. 149,169 180

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Summary of the Regulatory Commitments

1. LCS 1.7.3 will be revised to reference TS LCO 3.0.8 during the implementation of the approved amendment.

2. The LCO 3.0.8 Bases will be incorporated into the TS Bases during the implementation of the approved amendment in accordance with the existing TS Bases Control Program (reference TS 5.5.10).

APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADD LCO 3.0.8 ON THE INOPERABILITY OF SNUBBERS (TSTF-372) USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Proposed Technical Specifications Bases Changes (mark-up)

LCO Applicability 3 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASESS LCOs LCO 3.0.1 through LCO 3.0 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met.

The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered.

The Required Actions establish those remedial measures that must be taken wi,:hin specified Completion Times when the requirements of an LCO are not met.

This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b.

Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions.

The first type of Required Action specifies a time limit in which the LCO must be met.

This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits.

If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable.

(Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering (continued)

Columbia Generating Station B 3.0-1 Revision 241

LCO Applicability B 3.0 BASES (continued)

I LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.

Unless otherwise specified, all the other TS requirements remain unchanged.

This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Special OperatiDns LCOs is optional.

A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements.

If it is desired to perform-the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed.

When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO).

However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCO's ACTIONS be met,. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO.

If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required *to be met concurrent with the requirements of the Special Operations LCO.

=

se Qt

+

\\E 3 o 8 Columbia Generating Station B 3.0-11 Revision 36

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remail 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 considered 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 b 9 declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.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 3.0.8.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 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 3.0.8.b applies when one or more snubbers are not capable of providing their associated support functlon(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.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 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

LCO 3.0.8 requires that risk be assessed and managed. 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 3.0.8 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 bei a qualitative awareness of the vulnerability of systems and components when cone or more snubbers are not able to perform their associated support function.