3F0307-08, License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process

License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process

ML070750096
Person / Time
Site:	Crystal River
Issue date:	03/14/2007
From:	Roderick D Progress Energy Co
To:	Document Control Desk, NRC/NRR/ADRO
References
3F0307-08
Download: ML070750096 (20)

Text

aProgress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.90 March 14, 2007 3F0307-08 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process

Reference:

Crystal River Unit 3 to NRC letter dated December 14, 2006, "License Amendment Request No. 291, Revision 0, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process" Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., hereby provides Revision 1 to License Amendment Request #291. The proposed amendment would revise the Crystal River Unit 3 (CR-3) Improved Technical Specification (ITS) to include Limiting Condition for Operation (LCO) 3.0.8 for the inoperability of snubbers. This submittal is consistent with NRC-approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-372, "Inoperability of Snubbers." This submittal replaces the referenced letter, License Amendment Request No. 291, Revision 0, in its entirety.

The approved TSTF-372, Revision 4 includes a revision to LCO 3.0.1. This revision proposes to add the new LCO 3.0.8 as an exception to LCO 3.0.1. This addition was inadvertently omitted in the referenced letter. Attachment 2 provides this marked up page in addition to those in the referenced submittal. This proposed ITS revision is considered administrative. The inclusion of this change to LCO 3.0.1, does not affect the No Significant Hazards Determination or Environmental Analysis previously provided in the referenced letter. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing ITS pages marked with strikeout and shadowed text to show the proposed changes. Attachment 3 provides revised ITS pages with revision lines. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing ITS Bases pages marked up to show the proposed change (for information only).

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Powerline Street.

Crystal River, FL 34428

U.S. Nuclear Regulatory Commission Page 2 of 3 3F0307-08 PEF requests approval of the proposed License Amendment by July 31, 2007, with the amendment being implemented within ninety days of issuance.

The CR-3 Plant Nuclear Safety Committee has reviewed this request and recommended it for approval.

If you should have any questions regarding this submittal, please contact Mr. Paul Infanger, Supervisor, Licensing & Regulatory Programs at (352) 563-4796.

Daniel L. Roderick Director Site Operations Crystal River Nuclear Plant Attachments: 1. Description and Assessment

2. Proposed Revised Improved Technical Specification Pages -

Strikeout/Shadowed Format

3. Proposed Revised Improved Technical Specification Pages - Revision Bar Format

4. Regulatory Commitment

5. Proposed Improved Technical Specification Bases Pages xc: NRC Project Manager NRC Regional Office NRC Resident Inspector

U.S. Nuclear Regulatory Commission Page 3 of 3 3F0307-08 STATE OF FLORIDA COUNTY OF CITRUS Daniel L. Roderick states that he is the Director Site Operations, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, informa and belief.

Daniel L. Roderick Director Site Operations Crystal River Nuclear Plant The foregoing document was acknowledged before me this day of 4 k 2007, by Daniel L. Roderick.

Signature of Nota Public State of Florida (Print, type, or stamp Commissioned Name of Notary Public)

Personally / Produced Known -OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process ATTACHMENT 1 Description and Assessment

U.S. Nuclear Regulatory Commission Attachment 1 3F0307-08 Page 1 of 3 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify Improved Technical Specifications (ITS) requirements for inoperable snubbers by adding specification 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.

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 ITS 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 Florida Power Corporation, (FPC) 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 well as the supporting information provided to support TSTF-372. FPC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Crystal River Unit 3 (CR-3) and justify this amendment for the incorporation of the changes to the CR-3 ITS.

U.S. Nuclear Regulatory Commission Attachment 1 3F0307-08 Page 2 of 3 2.2 Optional Changes and Variations FPC is proposing a variation to the ITS changes described in TSTF-372 Revision 4.

CR-3 ITS conversion Amendment No. 149, was approved prior to Revision 0 of NUREG 1430, "Standard Technical Specifications for Babcock and Wilcox Plants, Specifications." This revision of the ITS, did not include an exception for LCO 3.0.7 in LCO 3.0.1. This addition is proposed for consistency with the NUREG and TSTF-372.

This proposed ITS revision is considered administrative.

LCO 3.0.7, PHYSICS TEST Exception LCOs (Specification 3.1.8 and 3.1.9) allows specified ITS requirements to be suspended to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of the ITS. Unless otherwise specified, all other ITS requirements remain unchanged. This ensures 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 inclusion of LCO 3.0.7 in LCO 3.0.1, does not affect the No Significant Hazards Determination or Environmental Analysis.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination FPC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister as part of the CLIIP. FPC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to CR-3 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 ITS improvement, plant-specific verifications were performed as follows:

1. Appropriate plant procedures and administrative controls will be used to implement the following Tier 2 Restrictions.

a. At least one Emergency Feedwater Train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) will be available when LCO 3.0.8a is used at CR-3.

b. At least one Emergency Feedwater Train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) or an alternative means of core cooling, Feed and Bleed (HPI/PORV cooling), will be available when LCO 3.0.8b is used at CR-3.

c. Not applicable to CR-3.

d. Not applicable to CR-3.

U.S. Nuclear Regulatory Commission Attachment 1 3F0307-08 Page 3 of 3

e. Every time the provisions of LCO 3.0.8 are used CR-3 will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers will remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. A record of the design function of the inoperable snubber (i.e. seismic vs.

non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration will be available on a recoverable basis for staff inspection.

2. CR-3 will use qualitative and quantitative evaluation per IOCFR50.65(a)(4), the Maintenance Rule when invoking Technical Specification 3.0.8.

FPC will establish ITS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. This guidance will include the verifications in L.a.,

1.b. and i.e. as written above. LCO 3.0.8 requires that risk be managed and assessed.

The Bases will 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. Finally, the licensee is expected to have a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION FPC has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005 as part of the CLIIP. FPC has concluded that the staff's findings presented in that evaluation are applicable to CR-3 and the evaluation is hereby incorporated by reference for this application.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process ATTACHMENT 2 PROPOSED REVISED IMPROVED TECHNICAL SPECIFICATION PAGES STRIKEOUT/SHADOWED FORMAT S#Weet-Text Indicates Deleted Text dIndicates Added Text

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 3.0O.22'AlýOVOMS37M'P-C! _O.

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 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, except as provided in the associated ACTIONS, and an associated ACTION is not met or provided, the unit shall be placed in a MODE or other specified condition in which the Specification 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 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

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

c. MODE 5 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, 3, and 4.

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; or (continued)

Crystal River Unit 3 3.0-1 Amendment No. 2+5

LCO Applicability 3.0 3.0 LCO APPLICABILITY LI 3.0.6 When a support system's Required Action directs a supported (continued) 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.

LCD 3.0.7 PHYSICS TESTS Exception LCOs (Specification 3.1.8 and 3.1.9) allow specified Technical Specifications (TS) requirements to be suspended to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with PHYSICS TESTS Exception LCOs is optional. When a PHYSICS TEST Exception LCO is desired to be met but is not met, the ACTIONS of the PHYSICS TESTS Exception LCO shall be met.

When a PHYSICS TEST Exception 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 other applicable Specifications.

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s ieU Crystal River Unit 3 3.0-3 Amendment No. +0

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50- 302/ LICENSE NUMBER DPR- 72 License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process ATTACHMENT 3 PROPOSED REVISED IMPROVED TECHNICAL SPECIFICATION PAGES REVISION BAR FORMAT

LCO Applicability LCO 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, LCO 3.0.7 and LCO 3.0.8.

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 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, except as provided in the associated ACTIONS, and an associated ACTION is not met or provided, the unit shall be placed in a MODE or other specified condition in which the Specification 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 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

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

c. MODE 5 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, 3, and 4.

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; or (continued)'

Crystal River Unit 3 3.0-1 Amendment No.

LCO Applicability LCO 3.0 3.0 LCO APPLICABILITY LCO 3.0.6 When a support system's Required Action directs a supported (continued) 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 PHYSICS TESTS Exception LCOs (Specification 3.1.8 and 3.1.9) allow specified Technical Specifications (TS) requirements to be suspended to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with PHYSICS TESTS Exception LCOs is optional. When a PHYSICS TEST Exception LCO is desired to be met but is not met, the ACTIONS of the PHYSICS TESTS Exception LCO shall be met.

When a PHYSICS TEST Exception 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 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.

Crystal River Unit 3 3.0-3 Amendment No.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50- 302/ LICENSE NUMBER DPR- 72 License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process ATTACHMENT 4 REGULATORY COMMITMENT

U.S. Nuclear Regulatory Commission Attachment 4 3F0307-08 Page 1 of 1 Regulatory Commitments The following table identifies those actions committed to by Florida Power Corporation (FPC) 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 Mr. Paul Infanger, Supervisor, Licensing & Regulatory Programs at (352) 563-4796.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER - UNIT 3 DOCKET NUMBER 50- 302/ LICENSE NUMBER DPR- 72 License Amendment Request No. 291, Revision 1, Application for Improved Technical Specification Change to Add LCO 3.0.8 on the Operability of Snubbers Using the Consolidated Line Item Improvement Process ATTACHMENT 5 PROPOSED IMPROVED TECHNICAL SPECIFICATION BASES PAGES

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications 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 MODE 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 within 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 Times, 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 ACTIONS. The second type of Required Action specifies the (continued)

Crystal River Unit 3 B 3.0-1 Revision No.

LCO Applicability B 3.0 BASES 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.

PHYSICS TESTS Exceptions LCOs (Specification 3.1.8 and 3.1.9) allow specified TS requirements to be suspended 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 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.

Compliance with PHYSICS TESTS Exception LCO is optional. A special operation may be performed either under the provisions of the appropriate PHYSICS TESTS Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the PHYSICS TESTS Exception LCO, the requirements of the PHYSICS TESTS Exception LCO shall be followed. The surveillances of the other LCO are not required to be met, unless specified in the PHYSICS TESTS Exception LCO.

LCO 3.0.8 LCO 3.0.8 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 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 ITS under licensee control. LCO 3.0.8 applies to snubbers that have seismic function only. It does not apply to snubbers that also have design functions to mitigate steam/water hammer or other transient loads. 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.

When a snubber is to be rendered incapable of performing its related support function (i.e., nonfunctional) for testing or maintenance or is discovered to not be functional, it must be determined whether any system(s) require the affected (continued)

Crystal River Unit 3 B 3.0-16 Revision No.

LCO Applicability B 3.0 BASES LCO 3.0.8 snubber(s) for system OPERABLILITY, and whether the plant is (continued) in a MODE or specified condition in the Applicability that requires the supported system(s) to be OPERABLE.

If an analysis determines that the supported system(s) do not require the snubber(s) to be functional in order to support the OPERABILITY of the system(s), LCO 3.0.8 is not needed. IF the LCO(S) associated with any supported system(s) are not currently applicable (i.e., the plant is not in a MODE or other specified condition in the Applicability of the LCO), LCO 3.0.8 is not needed. If the supported system(s) are inoperable for reasons other than snubbers, LCO 3.0.8 cannot be used. LCO 3.0.8 is an allowance, not a requirement. When a snubber is nonfunctional, any supported system(s) may be declared inoperable instead of using LCO 3.0.8.

Every time the provisions of LCO 3.0.8 are used, CR-3 will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers will remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.

LCO 3.0.8 does not apply to non-seismic snubbers. A record of the design function of the inoperable snubber (i.e.,

seismic vs. non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration will be available on a recoverable basis for NRC staff inspection. The applicable action for each snubber (LCO 3.0.8.a, LCO 3.0.8.b or engineering evaluation required) will be listed in the Equipment Database (EDB).

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 3.0.2.

LCO 3.O.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 (continued)

Crystal River Unit 3 B 3.0-17 Revision No.

LCO Applicability B 3.0 BASES LCO 3.0.8 due to the availability of the redundant train of the supported (continued) system. At least one Emergency Feedwater Train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) will be available when LCO 3.O.8.a is used at CR-3.

LCO 3.0.8.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 3.0.8.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.

For snubbers that impact both trains of EFW, HPI/PORV cooling capability must be verified before utilizing 3.0.8.b. At least one Emergency Feedwater Train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) or an alternative means of core cooling, HPI/PORV cooling, will be available when LCO 3.0.8.b is used at CR-3.

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 be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

Crystal River Unit 3 R 3-0-18 Revision No-