Text

Enclosure 2 - Volume 5 - Improved Technical Specifications Conversion, ITS Section 3.0, LCO and SR Applicability, Revision 0
	ML13329A855
Person / Time
Site:	Sequoyah
Issue date:	11/22/2013
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML13329A881	List: ML13329A717; ML13329A718; ML13329A790; ML13329A791; ML13329A792; ML13329A854; ML13329A855; ML13329A858; ML13329A859; ML13329A916; ML13330A922; ML13330A924; ML13330A925; ML13330A927; ML13330A928; ML13330A929; ML13330A930; ML13330A931; ML13330A953;
References
	NUREG-1431, Rev 4
	Download: ML13329A855 (90)
	v • d • e

Enclosure 2, Volume 5, Rev. 0, Page 1 of 90 ENCLOSURE 2 VOLUME 5 SEQUOYAH NUCLEAR PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.0 LCO AND SR APPLICABILITY Revision 0 Enclosure 2, Volume 5, Rev. 0, Page 1 of 90

Enclosure 2, Volume 5, Rev. 0, Page 2 of 90 LIST OF ATTACHMENTS

1. ITS Section 3.0, LCO and SR Applicability Enclosure 2, Volume 5, Rev. 0, Page 2 of 90

Enclosure 2, Volume 5, Rev. 0, Page 3 of 90 ATTACHMENT 1 ITS Section 3.0, LCO AND SR APPLICABILITY Enclosure 2, Volume 5, Rev. 0, Page 3 of 90

Enclosure 2, Volume 5, Rev. 0, Page 4 of 90 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Enclosure 2, Volume 5, Rev. 0, Page 4 of 90

Enclosure 2, Volume 5, Rev. 0, Page 5 of 90 A01 ITS ITS Section 3.0

.0 (LCO) 3/4 LIMITING CONDITIONS FOR OPEATION AND SURVEILLANCE REQUIREMENTS A01 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION LCOs shall be met LCO 3.0.1 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure A02 to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met and as provided in LCO 3.0.7. in the Applicability, LCO 3.0.2, LCO 3.0.7, 3.0.8, and LCO 3.0.9 LCO 3.0.2 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 A02 Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required. INSERT 1 an LCO and A03 S

LCO 3.0.3 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION INSERT 2 requirements, within one hour action shall be initiated to place the unit in a MODE in which the A04 Specification does not apply by placing it, as applicable, in:

MODE 3 7

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , A05 MODE 4 13 MODE 5

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 37

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

INSERT 3 Where corrective measures are completed that permit operation under the ACTION requirements, the A06 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. this specification A01 LCO 3.0.4 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 A01

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 See ITS applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power 3.8.1 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 October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-1 Amendment No. 202, 301, 312 Page 1 of 14 Enclosure 2, Volume 5, Rev. 0, Page 5 of 90

Enclosure 2, Volume 5, Rev. 0, Page 6 of 90 ITS Section 3.0 A02 A03 INSERT 1 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.

INSERT 2 are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, A04 the unit shall be placed in a MODE or other specified condition in which the LCO is not A01 applicable.

A06 INSERT 3 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.

Insert Page 3/4 0-1 Page 2 of 14 Enclosure 2, Volume 5, Rev. 0, Page 6 of 90

Enclosure 2, Volume 5, Rev. 0, Page 7 of 90 A01 ITS ITS Section 3.0 APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 3.0.5 (Continued) conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , See ITS

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 3.8.1

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This Specification is not applicable in MODES 5 or 6.

LCO 3.0.5 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 A07 returned to service under administrative control to perform the testing required to demonstrate A08 OPERABILITY. INSERT 4 INSERT 5 A09 LCO 3.0.8 3.0.7 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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.

INSERT 6 L01 3.0 (SR) APPLICABILITY SURVEILLANCE REQUIREMENTS SRs SR 3.0.1 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the LCOs SR 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 A01 experienced during the performance of the Surveillance or between performances of the Surveillance, LCO Frequency shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the SR 3.0.3 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.

A10 SR 3.0.2 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. INSERT 7 L02 Frequency M01 SR 3.0.3 4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval A01 LCO (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare A11 the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency A01 or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. 78, 162, 202, 208, 274, 280, 293, 312 Page 3 of 14 Enclosure 2, Volume 5, Rev. 0, Page 7 of 90

Enclosure 2, Volume 5, Rev. 0, Page 8 of 90 ITS Section 3.0 A08 INSERT 4 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

A09 INSERT 5 LCO 3.0.7 Test Exception LCO 3.1.8, PHYSICS TEST Exceptions - MODE 2" allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

Insert Page 3/4 0-2a Page 4 of 14 Enclosure 2, Volume 5, Rev. 0, Page 8 of 90

Enclosure 2, Volume 5, Rev. 0, Page 9 of 90 ITS Section 3.0 L01 INSERT 6 LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

INSERT 7 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 A10 measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply. M01 If a Completion Time requires periodic performance on a "once per . . ." basis, the above L02 Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications. A10 Insert Page 3/4 0-2b Page 5 of 14 Enclosure 2, Volume 5, Rev. 0, Page 9 of 90

Enclosure 2, Volume 5, Rev. 0, Page 10 of 90 A01 ITS ITS Section 3.0 SURVEILLANCE REQUIREMENTS (Continued) 4.0.3 (Continued)

LCO SR 3.0.3 If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must Condition immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance A01 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. LCO Condition SR 3.0.4 4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 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:

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

b. The provisions of SR 4.0.2 are applicable to the frequencies for performing inservice inspection activities;

c. Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and See ITS 5.5 c.4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at 20-year intervals (the provisions of SR 4.0.2 are not applicable); and

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

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

a. Provisions that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as required by 10 CFR 50.55a; October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-3 Amendment No. 78, 162, 202, 208, 274, 280, 293, 301, 308 Page 6 of 14 Enclosure 2, Volume 5, Rev. 0, Page 10 of 90

Enclosure 2, Volume 5, Rev. 0, Page 11 of 90 A01 ITS ITS Section 3.0 APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued) 4.0.5 (Continued)

b. Testing Frequencies applicable to the ASME OM Code and applicable Addenda as follows:

ASME OM Code and applicable Addenda Required frequencies for terminology for inservice performing inservice testing activities testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days See ITS Semiannually or every 6 months At least once per 184 days 5.5 Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

c. The provisions of SR 4.0.2 are applicable to the above required Frequencies and other normal and accelerated frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities;

d. The provisions of SR 4.0.3 are applicable to inservice testing and activities; and

e. Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.

October 4, 2006 SEQUOYAH - UNIT 1 3/4 0-4 Amendment No. 78, 162, 202, 208, 274, 280, 293, 308 Page 7 of 14 Enclosure 2, Volume 5, Rev. 0, Page 11 of 90

Enclosure 2, Volume 5, Rev. 0, Page 12 of 90 ITS A01 (LCO)

ITS Section 3.0

.0 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS A01 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION LCOs shall be met LCO 3.0.1 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure A02 to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met and as provided in LCO 3.0.7. in the Applicability, LCO 3.0.2, LCO 3.0.7, 3.0.8, and LCO 3.0.9 LCO 3.0.2 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 A02 Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required. INSERT 1 an LCO and S A03 LCO 3.0.3 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION INSERT 2 requirements, within one hour action shall be initiated to place the unit in a MODE in which the A04 Specification does not apply by placing it, as applicable, in:

MODE 3 7

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 13 A05 MODE 4

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 37 MODE 5

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

INSERT 3 Where corrective measures are completed that permit operation under the ACTION requirements, the A06 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. this specification A01 LCO 3.0.4 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 A01

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 See ITS applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power 3.8.1 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 October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-1 Amendment No. 192, 290, 301 Page 8 of 14 Enclosure 2, Volume 5, Rev. 0, Page 12 of 90

Enclosure 2, Volume 5, Rev. 0, Page 13 of 90 ITS Section 3.0 A02 A03 INSERT 1 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.

INSERT 2 are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, A04 the unit shall be placed in a MODE or other specified condition in which the LCO is not A01 applicable.

A06 INSERT 3 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.

Insert Page 3/4 0-1 Page 9 of 14 Enclosure 2, Volume 5, Rev. 0, Page 13 of 90

Enclosure 2, Volume 5, Rev. 0, Page 14 of 90 ITS A01 ITS Section 3.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.5 (Continued) conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months See ITS

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 3.8.1

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This Specification is not applicable in MODES 5 or 6.

LCO 3.0.5 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 A07 returned to service under administrative control to perform the testing required to demonstrate A08 OPERABILITY. INSERT 4 INSERT 5 A09 LCO 3.0.8 3.0.7 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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.

INSERT 6 L01 3.0 (SR) APPLICABILITY SURVEILLANCE REQUIREMENTS SRs SR 3.0.1 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the LCOs SR 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 A01 experienced during the performance of the Surveillance or between performances of the Surveillance, LCO Frequency 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 SR 3.0.3 provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

A10 SR 3.0.2 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. INSERT 7 L02 Frequency M01 SR 3.0.3 4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval A01 LCO (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare A11 the Limiting Condition for Operation not met may be delayed, from the time of discovery, A01 October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-2 Amendment No. 69, 152, 192, 198, 263, 271, 283, 301 Page 10 of 14 Enclosure 2, Volume 5, Rev. 0, Page 14 of 90

Enclosure 2, Volume 5, Rev. 0, Page 15 of 90 ITS Section 3.0 A08 INSERT 4 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

A09 INSERT 5 LCO 3.0.7 Test Exception LCO 3.1.8, PHYSICS TEST Exceptions - MODE 2" allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

Insert Page 3/4 0-2a Page 11 of 14 Enclosure 2, Volume 5, Rev. 0, Page 15 of 90

Enclosure 2, Volume 5, Rev. 0, Page 16 of 90 ITS Section 3.0 L01 INSERT 6 LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

INSERT 7 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 A10 measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply. M01 If a Completion Time requires periodic performance on a "once per . . ." basis, the above L02 Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications. A10 Insert Page 3/4 0-2b Page 12 of 14 Enclosure 2, Volume 5, Rev. 0, Page 16 of 90

Enclosure 2, Volume 5, Rev. 0, Page 17 of 90 ITS A01 ITS Section 3.0 APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued) 4.0.3 (Continued)

Frequency up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater. This delay A01 period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed. LCO SR 3.0.3 If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must Condition immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance A01 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. LCO Condition SR 3.0.4 4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 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:

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

b. The provisions of SR 4.0.2 are applicable to the frequencies for performing inservice inspection activities; See ITS 5.5

c. Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c.4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at 20-year intervals (the provisions of SR 4.0.2 are not applicable); and

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

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

October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-3 Amendment No. 69, 152, 198, 263, 271, 283, 290 Page 13 of 14 Enclosure 2, Volume 5, Rev. 0, Page 17 of 90

Enclosure 2, Volume 5, Rev. 0, Page 18 of 90 ITS A01 ITS Section 3.0 APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued) 4.0.5 (Continued)

a. Provisions that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as required by 10 CFR 50.55a;

b. Testing frequencies applicable to the ASME OM Code and applicable Addenda as follows:

ASME OM Code and applicable Addenda Required frequencies for terminology for inservice performing inservice testing activities testing activities Weekly At least once per 7 days See ITS Monthly At least once per 31 days 5.5 Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

c. The provisions of SR 4.0.2 are applicable to the above required Frequencies and other normal and accelerated frequencies specified as 2 years or less in the Inservice Test Program for performing inservice testing activities;

d. The provisions of SR 4.0.3 are applicable to inservice testing and activities; and

e. Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.

October 4, 2006 SEQUOYAH - UNIT 2 3/4 0-4 Amendment No. 69, 152, 198, 263, 271, 283, 297 Page 14 of 14 Enclosure 2, Volume 5, Rev. 0, Page 18 of 90

Enclosure 2, Volume 5, Rev. 0, Page 19 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev.

4.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 Compliance with the Limiting Conditions for Operation (LCO) contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met and as provided in LCO 3.0.7." ITS LCO 3.0.1 states, "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, LCO 3.0.8, and LCO 3.0.9." This results in several changes to the CTS.

Certain phrases are revised to be consistent with the equivalent phrase used in the ITS. Specifically, "OPERATIONAL MODES or other conditions specified therein" is changed to "MODES or other specified conditions in the Applicability" to be consistent with the ITS definition of MODE and the terminology used in the ITS.

These changes are acceptable because they result in no change in the intent or application of the Technical Specifications, but merely reflect editorial preferences used in the ITS.

The phrase "Compliance with the LIMITING CONDITIONS FOR OPERATION contained in the succeeding Specifications is required" is replaced with "LCOs shall be met." This change is made consistent with the ITS.

This change is acceptable because it is an editorial change that does not change the intent of the requirements.

The phrase "except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met" is moved from CTS 3.0.1 to ITS LCO 3.0.2, which states in part, "Upon discovery or failure to meet an LCO, the Required Actions of the associated Conditions shall be met."

The change is acceptable because moving this information within the Technical Specifications results in no change in the intent or application of ACTIONS.

Sequoyah Unit 1 and 2 Page 1 of 10 Enclosure 2, Volume 5, Rev. 0, Page 19 of 90

Enclosure 2, Volume 5, Rev. 0, Page 20 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY

The phrase "except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9" is added in ITS LCO 3.0.1. ITS LCO 3.0.2 describes the appropriate actions to be taken when ITS LCO 3.0.1 is not met. ITS LCO 3.0.7 describes Test Exceptions LCOs, which are exceptions to other LCOs. ITS LCO 3.0.8 addresses snubber inoperabilities, which is also an exception to other LCOs. ITS LCO 3.0.9 addresses barrier inoperabilities which is also an exception to other LCOs. Changes resulting from the incorporation of ITS LCO 3.0.9 are discussed in Discussion of Change (DOC) L01.

This change is acceptable because adding the exceptions for ITS LCO 3.0.2, LCO 3.0.6, LCO 3.0.7, and LCO 3.0.9 prevent a conflict within the Applicability section. This addition is needed for consistency in the ITS requirements and does not change the intent or application of the Technical Specifications.

Furthermore, changing the CTS LCO 3.0.7 to ITS LCO 3.0.8 does not change the intent of the snubber exception.

A03 CTS 3.0.2 states, "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 intervals, completion of the ACTION requirements is not required." ITS LCO 3.0.2 states "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." This results in several changes to the CTS.

CTS 3.0.2 is revised to include an exception for ITS LCO 3.0.6. ITS LCO 3.0.6 is a new allowance that takes exception to the ITS LCO 3.0.2 requirement to take the associated ACTION requirements when a LIMITING CONDITION FOR OPERATION is not met. This exception is included in ITS LCO 3.0.2 to avoid conflict between the applicability requirements.

This change is acceptable because it includes a reference to a new item in the ITS and results in no change to the CTS. Changes resulting from the incorporation of ITS LCO 3.0.6 are discussed in DOC A07.

The second sentence of CTS 3.0.2 states, "If the LIMITING CONDITIONS FOR OPERATION is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required." The sentence is changed, in ITS LCO 3.0.2, to state "If the LCO is not 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."

This change is acceptable because, while worded differently, both the CTS and ITS state that ACTIONS do not have to be completed once the LCO is met or is no longer applicable. ITS LCO 3.0.2 also adds the phrase "unless otherwise stated." There are some ITS ACTIONS that must be completed, Sequoyah Unit 1 and 2 Page 2 of 10 Enclosure 2, Volume 5, Rev. 0, Page 20 of 90

Enclosure 2, Volume 5, Rev. 0, Page 21 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY even if the LCO is met or is no longer applicable. This change is acceptable because it reflects a new feature in the ITS which does not exist in the CTS.

The technical aspects of these changes are discussed in the appropriate ITS sections.

These changes are designated as administrative because they are editorial and do not result in technical changes to the Technical Specifications.

A04 CTS 3.0.3, in part, is applicable "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements." ITS LCO 3.0.3 expands those applicability requirements so that the requirement is applicable "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." This changes the CTS to add two new applicability conditions.

ITS LCO 3.0.3 is applicable when the LCO is not met and there is no applicable ACTION to be taken.

This change is acceptable because it is consistent with the current understanding and application of CTS 3.0.3.

ITS LCO 3.0.3 is applicable when directed by the associated ACTIONS. The CTS and the ITS contain such requirements. Any technical changes related to directing LCO 3.0.3 entry in an ACTION will be discussed in the affected Technical Specifications.

This change is acceptable because it is consistent with the current understanding and application of CTS 3.0.3.

These changes are designated as administrative because they do not result in any technical changes to the Technical Specifications.

A05 CTS 3.0.3, in part, states that 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: Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Hot Shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and at least Cold Shutdown within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS LCO 3.0.3 states that action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . This changes the CTS by using the sum of the times (i.e., the ITS Completion Time of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to enter MODE 5 is the same as the sum of the CTS allowance of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) instead of sequential times (i.e., each time is measured from the completion of the previous step). The stated times in CTS 3.0.3 and ITS 3.0.3 are listed below:

Sequoyah Unit 1 and 2 Page 3 of 10 Enclosure 2, Volume 5, Rev. 0, Page 21 of 90

Enclosure 2, Volume 5, Rev. 0, Page 22 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Mode Title CTS Time to Enter Mode ITS Time to Enter Mode

-- (Current Mode) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to begin action 3 Hot Standby within the next 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 6 hours 4 Hot Shutdown within the following 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months 6 hours 5 Cold Shutdown within the subsequent 24 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months hours The purpose of CTS 3.0.3 is to establish the shutdown requirements that must be implemented when an LCO is not met and the condition is not specifically addressed in the associated ACTION requirements. The delineated time limit allows the unit to be placed in a safe shutdown MODE when the plant cannot be maintained within the limits for safe operation. The time limit, specified in CTS 3.0.3 to reach the lower MODES of operation, permits the shutdown to proceed in a controlled manner that is well within the specified maximum cooldown rate.

Furthermore, the time limit is within the cooldown capabilities of the plant assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies. In the CTS, this is accomplished by allowing a total of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in Cold Shutdown when a shutdown is required during the MODE of Operation. In the absence of specific guidance within the CTS, current SQN practice if the unit is in a lower MODE of Operation and a CTS 3.0.3 shutdown is required, is to apply the time limit for reaching the lower MODE of operation (i.e., each time limit is measured from the time the previous MODE is reached). In the ITS, the time limits for ITS LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower mode of operation when an ITS LCO 3.0.3 shutdown is required, the time limit for reaching the next lower MODE applies (i.e., if the plant is in MODE 3, 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months is allowed to reach MODE 4). ITS 3.0 Bases gives a detailed discussion on the use of applying the allowed outage times when the unit is in a lower MODE when ITS 3.0.3 is entered. This is further explained, with examples, in the discussion of Section 1.3, "Completion Times." This change is acceptable because ITS and CTS both allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to reach MODE 5 from power operation. In addition, the CTS 3.0.3 statement "

within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply" has been editorially reworded in ITS LCO 3.0.3 to "the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. ACTION shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit..."

These changes are considered changes to the CTS presentation. These changes are designated as administrative as they apply rules of usage established by ITS without resulting in technical changes to the Technical Specifications.

A06 CTS 3.0.3 states "Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in Sequoyah Unit 1 and 2 Page 4 of 10 Enclosure 2, Volume 5, Rev. 0, Page 22 of 90

Enclosure 2, Volume 5, Rev. 0, Page 23 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation." ITS LCO 3.0.3 states "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 applicable in MODES 1, 2, 3, and 4."

This change is acceptable because the changes to CTS 3.0.3 are editorial. Both the CTS and ITS state that LCO 3.0.3 can be exited if the LCO which led to the entry into LCO 3.0.3 is met, or if one of the ACTIONS of that LCO is applicable.

The CTS requirement also specifies that the time to complete the ACTIONS in the LCO is based on the initial failure to meet the LCO. Reentering the LCO after exiting LCO 3.0.3 does not reset the ACTION statement time requirements. This information is not explicitly stated in ITS LCO 3.0.3 but is true under the multiple condition entry concept of the ITS. In addition, the sentence "LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4" is added to ITS LCO 3.0.3. CTS 3.0.3 and ITS LCO 3.0.3 require the unit to be placed only as low as COLD SHUTDOWN (MODE 5). Once the unit is in MODE 5, there are no further requirements.

Thus, CTS 3.0.3 and ITS LCO 3.0.3 are effectively only applicable in MODES 1, 2, 3, and 4, and the addition of the sentence merely reflects editorial preferences used in the ITS.

These changes are designated as administrative because there is no change in the intent or application of the CTS 3.0.3 requirements.

A07 CTS 3.0.6 has a statement that CTS 3.0.6 is an exception to both CTS 3.0.1 and CTS 3.0.2. ITS LCO 3.0.5 includes only a statement that ITS LCO 3.0.5 is an exception to LCO 3.0.2. The statement that ITS LCO 3.0.5 is an exception to LCO 3.0.1 is not included.

This change is acceptable since ITS LCO 3.0.5 does not modify ITS LCO 3.0.1.

The ACTION requirements discussion that is in CTS 3.0.1 has been moved to ITS LCO 3.0.2 (i.e., it is not included in ITS LCO 3.0.1). This change is designated as administrative since it does not result in any technical change to the Technical Specifications.

A08 ITS LCO 3.0.6 is added to the CTS to provide guidance regarding the appropriate ACTIONS to be taken when a single inoperability (a support system) also results in the inoperability of one or more related systems (supported system(s)). ITS LCO 3.0.6 states "When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in Sequoyah Unit 1 and 2 Page 5 of 10 Enclosure 2, Volume 5, Rev. 0, Page 23 of 90

Enclosure 2, Volume 5, Rev. 0, Page 24 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY accordance with LCO 3.0.2." In the CTS, based on the intent and interpretation provided by the NRC over the years, there has been an ambiguous approach to the combined support/supported inoperability. Some of this history is summarized below:

Guidance provided in the June 13, 1979, NRC memorandum from Brian K.

Grimes (Assistant Director for Engineering and Projects) to Samuel E. Bryan (Assistant Director for Field Coordination) would indicate an intent/interpretation consistent with the proposed LCO 3.0.6, without the necessity of also requiring additional ACTIONS. That is, only the inoperable support system ACTIONS need be taken.

Guidance provided by the NRC in their April 10, 1980, letter to all Licensees, regarding the definition of OPERABILITY and its impact as a support system on the remainder of the CTS, would indicate a similar philosophy of not taking ACTIONS for the inoperable supported equipment. However, in this case, additional actions (similar to the proposed Safety Function Determination Program actions) were addressed and required.

Regulatory Issue Summary (RIS) 2005-20 and a reading of the CTS provide an interpretation that inoperability, even as a result of a Technical Specification support system inoperability, requires all associated ACTIONS to be taken.

Certain CTS contain ACTIONS such as "Declare the {supported system}

inoperable and take the ACTIONS of {its Specification}." In many cases, the supported system would likely already be considered inoperable. The implication of this presentation is that the ACTIONS of the inoperable supported system would not have been taken without the specific direction to do so.

Considering the history of misunderstandings in this area, the WOG ISTS, NUREG-1431, Rev. 4, was developed with Industry input and approval of the NRC to include LCO 3.0.6 and a new program, Specification 5.5.13, "Safety Function Determination Program (SFDP)." This change is acceptable since its function is to clarify existing ambiguities and to maintain actions within the realm of previous interpretations. This change is designated as administrative because it does not technically change the Technical Specifications.

A09 ITS LCO 3.0.7 is added to the CTS. ITS LCO 3.0.7 states "Test Exception LCOs 3.1.8, "PHYSICS TEST Exceptions - MODE 2" allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications."

Sequoyah Unit 1 and 2 Page 6 of 10 Enclosure 2, Volume 5, Rev. 0, Page 24 of 90

Enclosure 2, Volume 5, Rev. 0, Page 25 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY This change is acceptable because the CTS contain test exception specifications that allow certain LCOs to not be met for the purpose of special tests and operations. However, the CTS does not contain the equivalent of ITS LCO 3.0.7.

As a result, there could be confusion regarding which LCOs are applicable during special tests. LCO 3.0.7 was crafted to avoid that possible confusion. LCO 3.0.7 is consistent with the use and application of CTS test exception Specifications and does not provide any new restriction or allowance. This change is designated as administrative because it does not technically change the Technical Specifications.

A10 CTS 4.0.2 states, "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." ITS SR 3.0.2 states, "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." This results in several changes to the CTS.

ITS SR 3.0.2 adds to the CTS "For Frequencies specified as "once," the above interval extension does not apply." This is described in DOC M01.

ITS SR 3.0.2 adds to the CTS "If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the initial performance." This is covered by DOC L02.

CTS 4.0.2 states, "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." ITS SR 3.0.2 states, in part, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency." This change is being made to be consistent with the ITS terminology and to clarify the concept of the specified SR Frequency being met.

This change is acceptable since it does not change the intent of the requirements.

ITS SR 3.0.2 is more specific regarding the state of the Frequency by stating, "as measured from the previous performance or as measured from the time a specified condition of the Frequency is met." This direction is consistent with the current use and application of the Technical Specifications.

This change is acceptable because the ITS intent is the same as the CTS requirement.

Sequoyah Unit 1 and 2 Page 7 of 10 Enclosure 2, Volume 5, Rev. 0, Page 25 of 90

Enclosure 2, Volume 5, Rev. 0, Page 26 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY

ITS SR 3.0.2 adds to the CTS "Exceptions to this Specification are stated in the individual Specifications."

This change is acceptable because it reflects practices used in the ITS that are not used in the CTS. Any changes to a Technical Specification, by inclusion of such an exception, will be addressed in the affected Technical Specification.

The changes, except as discussed in DOC M01 and DOC L02, are designated as administrative because they reflect presentation and usage rules of the ITS without making technical changes to the Technical Specifications.

A11 CTS 4.0.3 states, in part, "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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater." ITS SR 3.0.3 contains a similar requirement, but excludes the statement "(including the allowed extension per Specification 4.0.2)." This changes the CTS by not including the statement "(including the allowed extension per Specification 4.0.2)."

This change is acceptable because the statement in CTS 4.0.2 "(including the allowed extension per Specification 4.0.2)" is not needed to be repeated in ITS SR 3.0.3. ITS SR 3.0.2 allows a Surveillance to be performed within 1.25 times the interval specified in the Frequency. Therefore, there is no need to repeat in ITS SR 3.0.3 the allowance that is granted in ITS SR 3.0.2. This change is designated as administrative because it does not result in a technical change to the Technical Specifications.

MORE RESTRICTIVE CHANGES M01 CTS 4.0.2 states, "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." ITS SR 3.0.2 states, "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." This changes the CTS by adding "For Frequencies specified as "once," the above interval extension does not apply."

The remaining changes to CTS 4.0.2 are discussed in DOC A10 and DOC L02.

The purpose of the 1.25 extension allowance to Surveillance Frequencies is to allow for flexibility in scheduling tests. This change is acceptable because Frequencies specified as "once" are typically condition-based Surveillances in Sequoyah Unit 1 and 2 Page 8 of 10 Enclosure 2, Volume 5, Rev. 0, Page 26 of 90

Enclosure 2, Volume 5, Rev. 0, Page 27 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY which the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Frequency without extension in order to avoid operation in unacceptable conditions. This change is designated as more restrictive because an allowance to extend Frequencies by 25 percent is eliminated for some Surveillances.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 CTS Section 3.0 does not contain an allowance when barriers cannot support their support function. The proposed change to CTS 3.0, "LCO Applicability" adds a new LCO 3.0.9. The addition of LCO 3.0.9 to the CTS is to address barriers which cannot perform their related support function for Technical Specification systems. ITS LCO 3.0.9 allows barriers to be able to not perform their safety function for up to 30 days before declaring the supported system inoperable. Furthermore, due to this addition, an allowance is also needed in LCO 3.0.1. This allowance has been added.

Barriers are defined as doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, which are designed to provide for the performance of the safety function for the Technical Specification system after the occurrence of one or more initiating events.

The barrier which cannot perform its related support function will be evaluated and managed under the Maintenance Rule plant configuration control requirement, 10 CFR 50.65(a)(4), and the associated industry guidance (NUMARC 93-01, Revision 3). This provision is applicable whether the barrier is affected due to planned maintenance or due to a discovered condition. Should the risk assessment and risk management actions for a specific plant configuration or emergent condition not support the 30 day allowed time, the Maintenance Rule risk management determined allowed time and actions must be implemented or the supported systems LCO be considered not met.

Application of LCO 3.0.9 is dependent on the OPERABILITY of at least one train or subsystem of the supported Technical Specification system and the system's ability to mitigate the consequences of the specified initiating events. However, during the 30 day period allowed by LCO 3.0.9, there exists the possibility that the train or subsystem required to be OPERABLE will unexpectedly become inoperable. Absent any further consideration, this would likely result in both trains of a Technical Specification required system being declared inoperable Sequoyah Unit 1 and 2 Page 9 of 10 Enclosure 2, Volume 5, Rev. 0, Page 27 of 90

Enclosure 2, Volume 5, Rev. 0, Page 28 of 90 DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY (i.e., the train supported by the barriers to which LCO 3.0.9 was being applied and the emergent condition of the inoperable train). This would likely result in entering LCO 3.0.3 and a rapid plant shutdown. While this scenario is of low likelihood, it is of very high consequence to the licensee and, therefore, should be avoided unless necessary to avoid an actual plant risk. As a result, LCO 3.0.9 contains a provision which addresses the emergent condition of the required OPERABLE train or subsystem becoming inoperable while LCO 3.0.9 is being used. LCO 3.0.9 provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to either restore the inoperable train or subsystem or to cease relying on the provisions of LCO 3.0.9 to consider the train or subsystem supported by the affected barrier(s) OPERABLE. This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is not based on a generic risk evaluation, as it would be difficult to perform such an analysis in a generic fashion. Rather, plant risk during this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is managed using the contemporaneous risk assessment and management required by 10 CFR 50.65(a)(4) and recognizes the unquantified advantage to plant safety of avoiding a plant shutdown with the associated transition risk.

A risk impact of the 30 day allowance for barriers was performed. All Sequoyah initiating events are located on the table depicted in TSTF-427 OR Sequoyah has evaluated the use of LCO 3.0.9 for a barrier protecting against an initiating event not on the table located in TSTF-427 and calculated the frequency ranges within the ranges in the table so the above analysis is applicable for those initiators.

Therefore, LCO 3.0.9 can be utilized when inoperable barriers affect Systems, Structures, or Components (SSCs).

L02 CTS 4.0.2 states, "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." ITS SR 3.0.2 states, " 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." This changes the CTS by adding, " If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in DOC A10 and DOC M01.

This change is acceptable because the 25 percent Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions that must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time with extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because addition time is provided to perform some periodic Required Actions.

Sequoyah Unit 1 and 2 Page 10 of 10 Enclosure 2, Volume 5, Rev. 0, Page 28 of 90

Enclosure 2, Volume 5, Rev. 0, Page 29 of 90 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 5, Rev. 0, Page 29 of 90

Enclosure 2, Volume 5, Rev. 0, Page 30 of 90 CTS LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0.1 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, LCO 3.0.8, and LCO 3.0.9.

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

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

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

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , 2

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

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

Exceptions to this Specification are stated in the individual Specifications.

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

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

3.0.4 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;

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 2 SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.0-1 Rev. 4.0 1 Enclosure 2, Volume 5, Rev. 0, Page 30 of 90

Enclosure 2, Volume 5, Rev. 0, Page 31 of 90 CTS LCO Applicability 3.0 3.0 LCO Applicability 3.0.4 LCO 3.0.4 (continued)

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.

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

DOC A08 LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall 13 4

be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

s 3 DOC A09 LCO 3.0.7 Test Exception LCOs [3.1.8 and 3.4.19] allow specified Technical

, "PHYSICS TEST Specification (TS) requirements to be changed to permit performance of Exceptions - MODE 2," special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.0-2 Rev. 4.0 1 Enclosure 2, Volume 5, Rev. 0, Page 31 of 90

Enclosure 2, Volume 5, Rev. 0, Page 32 of 90 CTS LCO Applicability 3.0 3.0 LCO Applicability 3.0.7 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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.

DOC L01 LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.0-3 Rev. 4.0 1 Enclosure 2, Volume 5, Rev. 0, Page 32 of 90

Enclosure 2, Volume 5, Rev. 0, Page 33 of 90 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 4.0.1 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.

4.0.2 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.

4.0.3 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

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

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.0-4 Rev. 4.0 1 Enclosure 2, Volume 5, Rev. 0, Page 33 of 90

Enclosure 2, Volume 5, Rev. 0, Page 34 of 90 SR Applicability 3.0 3.0 SR Applicability 4.0.4 SR 3.0.4 (continued)

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.

SEQUOYAH UNIT 1 Amendment XXX Westinghouse STS 3.0-5 Rev. 4.0 1 Enclosure 2, Volume 5, Rev. 0, Page 34 of 90

Enclosure 2, Volume 5, Rev. 0, Page 35 of 90 CTS LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0.1 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, LCO 3.0.8, and LCO 3.0.9.