ML16210A227

Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing.

ML16210A227
Person / Time
Site:	Limerick
Issue date:	07/26/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16210A227 (26)

Text

.200 -xeloP Ww ke'lPett Squar, PA 1gCl48 Exelon Generation www. 'Xf>loncor'"l.c c m 10 CFR 50.90 July 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Application To Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing" Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications (TS) for Limerick Generating Station, Units 1 and 2 (LGS).

The proposed change revises the LGS TS equivalent (TS 4.0.5) to Improved Standard Technical Specifications Section 5.5, "lnservice Test (1ST) Program," to remove requirements duplicated in American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code) , as clarified by Code Case OMN-20, "lnservice Test Frequency." A newly defined term, "lnservice Testing Program," is added toTS Section 1.1, "Definitions." The proposed change to the TS is consistent with TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," with three variations. The three variations are: 1) the LGS TS are based on the GE Standard Technical Specifications wording contained in NUREG-0123 (Standard Technical Specifications for General Electric Boiling Water Reactors); 2) the 1ST Program remains in TS, with the current program wording removed, and clarification on the use of SR 4.0.2 and 4.0.3 added; and 3) this license amendment request also revises the lnservice Inspection (lSI) requirements currently contained in TS 4.0.5.

Additionally, an administrative change is being proposed that adds the word, "Specification," to Surveillance Requirement 4.6.1.4, in order to clarify a TS reference.

Attachment 1 provides a description and assessment of the proposed TS changes.

Attachment 2 provides the existing TS pages marked up to show the proposed changes.

Attachment 3 provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only.

U.S. Nuclear Regulatory Commission LAR- TS lnservice Testing Program Removal July 26, 2016 Page 2 Approval of the proposed amendment is requested by July 26, 2017 . Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this letter.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 261h of July 2016.

If you have any questions regarding this submittal, please contact Laura A. Lynch at (61 0) 765-5729.

Respectfully, om~to~

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: (1) Description and Assessment of Technical Specifications Changes (2) Proposed Technical Specification Changes (Mark-Up) for Limerick Generating Station, Units 1 and 2 (3) Revised Technical Specification Bases Changes (Information Only) for Limerick Generating Station, Units 1 and 2 cc: Regional Administrator- NRC Region I NRC Senior Resident Inspector- Limerick Generating Station R. R. Janati - Bureau of Radiation Protection, Commonwealth of Pennsylvania

Attachment 1 Description and Assessment of Technical Specifications Changes 1.0

SUMMARY

DESCRIPTION 2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration

4.0 ENVIRONMENTAL CONSIDERATION

Attachment 1 Description and Assessment of Technical Specifications Changes 1.0

SUMMARY

DESCRIPTION The proposed change revises the Technical Specifications (TS), Limerick Generating Station, Units 1 and 2 (LGS) equivalent (TS 4.0.5) to Standard Technical Specifications (STS) Section 5.5, "Inservice Test (IST) Program," to remove requirements duplicated in American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code), as clarified by Code Case OMN-20, "Inservice Test Frequency." A new defined term, "Inservice Testing Program," is added to TS Section 1.1, "Definitions. The proposed change to the TS is consistent with TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," with three variations, discussed in Section 2.2 below. Additionally, an administrative change is being proposed that adds the word, Specification, to Surveillance Requirement 4.6.1.4, in order to clarify a TS reference.

This license amendment request also revises the Inservice Inspection (ISI) requirements currently contained in TS 4.0.5. This is an administrative change, consistent with the conversion from the previous version of the NRC's Standard Technical Specifications (Standard Technical Specifications (STS) for General Electric Boiling Water Reactors, NUREG-0123) to NRC Improved Standard Technical Specifications (Standard Technical Specifications - General Electric BWR/4 Plants, NUREG-1433). This portion of TS 4.0.5 is governed by 10 CFR 50.55a, Codes and standards, and Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda, and does not meet the criteria of 10 CFR 50.36, Technical specifications.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the model safety evaluation referred to in the Federal Register Notice of Availability dated March 28, 2016. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-545. EGC concluded that the justifications presented in TSTF-545 and the model safety evaluation prepared by the NRC staff are applicable to LGS, and justify this amendment for the incorporation of the changes to LGSs TS. The variations provided below do not result in any technical conflict with the intent of TSTF-545 or the associated model Safety Evaluation (SE).

Limerick Generating Station, Units 1 and 2 were issued a construction permit on June 19, 1974 and the provisions of 10 CFR 50.55a(f)(2) are applicable.

2.2 Variations No technical variations are proposed in this amendment request. The following bulleted items identify administrative variations. These differences do not result in any technical conflict with the intent of TSTF-545 or the associated model Safety Evaluation (SE).

LGS TS are based on the previous version of the NRC's STS (NUREG-0123) and, therefore, the wording and format varies slightly from the NRC Improved Standard Technical Specifications (NUREG-1433) shown in TSTF-545, Revision 3, and the applicable parts of the NRC's model safety evaluation. This minor variation is administrative and does not affect the applicability of TSTF-545 to the LGS TS.

Page 1 of 4

Attachment 1 Description and Assessment of Technical Specifications Changes TSTF-545 deletes the IST program TS 5.5 (for Limerick, TS 4.0.5), and re-numbers all subsequent TS programs. This also impacts several TS Bases references. EGC proposes to revise the LGS TS 4.0.5, reference, now shown as The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The provisions of SR 4.0.2 and 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

This will not change the subsequent TS program numbers. The program numbers, including the Inservice Testing Program, are referenced in a wealth of station procedures. By maintaining the current program numbering, excessive administrative burden is avoided. Based on this approach, several TSTF-545 TS Bases markup pages associated with the TSTF-545 program numbering are not included in Attachment 3 of this application.

This license amendment request also revises the Inservice Inspection (ISI) requirements currently contained in TS 4.0.5. This is an administrative change, consistent with the conversion from the NRC's Standard Technical Specifications (Standard Technical Specifications for General Electric Boiling Water Reactors, NUREG-0123) to NRC Improved Standard Technical Specifications (Standard Technical Specifications -

General Electric BWR/4 Plants, NUREG-1433). NUREG-1433 does not contain ISI requirements. Requirements to perform inservice inspection of Class 1, 2, and 3 components in accordance with the American Society of Mechanical Engineers (ASME)

Section XI are contained in 10 CFR 50.55a and are governed by the ISI Program at LGS. The proposed change does not eliminate any inservice inspections. They are covered by the existing ISI Program required by 10 CFR 50.55a. Further, details for implementation of the ISI Program for piping identified in NRC Generic Letter 88-01 are included in the ISI Program, as referenced in the Updated Final Safety Analysis Report (UFSAR). Revision of this item in TS does not impact LGSs implementation or performance of the ISI Program.

An administrative change is being proposed that adds the word, Specification, to Surveillance Requirement 4.6.1.4, in order to clarify a TS reference.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Exelon Generation Company, LLC (EGC) requests adoption of the Technical Specification (TS) changes described in TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," which is an approved change, to the TS for Limerick Generating Station, Units 1 and 2 (LGS), with a variation to also revise the Inservice Inspection Program (ISI) in TS 4.0.5. The proposed change revises TS 4.0.5, Surveillance Requirements for Inservice inspection and testing of ASME Code Class 1, 2 & 3 components, by revising the Inservice Testing (IST) Program and ISI Program specification, to better clarify the usage of LGS TS 4.0.2 and 4.0.3.

Page 2 of 4

Attachment 1 Description and Assessment of Technical Specifications Changes Requirements in the IST Program that are duplicative of requirements in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code, as clarified by Code Case OMN-20, "Inservice Test Frequency" are removed. Similarly, the requirements in the ISI Program are removed, as they are a duplicative of requirements in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. Other requirements in TS 4.0.5 are eliminated because the Nuclear Regulatory Commission (NRC) has determined their appearance in the TS is contrary to regulations.

A new defined term, "Inservice Testing Program," is added, which references the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.55a(f). Exelon Generation Company, LLC (EGC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises TS 4.0.5, Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 & 3 components, by revising the Inservice Testing Program and Inservice Inspection Program specification.

Most requirements in the IST Program are removed, as they are duplicative of requirements in the ASME OM Code, as clarified by Code Case OMN-20, "Inservice Test Frequency." The remaining requirements in the TS Section 4.0.5, IST Program are eliminated because the NRC has determined their inclusion in the TS is contrary to regulations. A new defined term, "Inservice Testing Program," is added to the TS, which references the requirements of 10 CFR 50.55a(f).

Similarly, the requirements in the ISI Program are revised, as they are a duplicative of requirements in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

Performance of inservice testing or inservice inspection is not an initiator to any accident previously evaluated. As a result, the probability of occurrence of an accident is not significantly affected by the proposed change. Inservice test frequencies under Code Case OMN-20 are equivalent to the current testing period allowed by the TS with the exception that testing frequencies greater than two years may be extended by up to six months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to mitigate any accident previously evaluated as the components are required to be operable during the testing period extension. Performance of inservice tests utilizing the allowances in OMN-20 will not significantly affect the reliability of the tested components. As a result, the availability of the affected components, as well as their ability to mitigate the consequences of accidents previously evaluated, is not affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 3 of 4

Attachment 1 Description and Assessment of Technical Specifications Changes

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not alter the design or configuration of the plant. The proposed change does not involve a physical alteration of the plant; no new or different kind of equipment will be installed. The proposed change does not alter the types of inservice testing or inservice inspection performed. In most cases, the frequency of inservice testing and inservice inspection is unchanged. However, the frequency of testing or inspection would not result in a new or different kind of accident from any previously evaluated since the testing methods are not altered.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change eliminates some provisions from the TS in lieu of provisions in the ASME Code, as modified by use of Code Case OMN-20 (IST) or ASME Boiler and Pressure Vessel Code (ISI). Compliance with the ASME Code is required by 10 CFR 50.55a. The proposed change also allows inservice tests with frequencies greater than two years to be extended by six months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to respond to an accident as the components are required to be operable during the testing period extension. The proposed change will eliminate the existing TS SR 4.0.2 allowance to perform a specified surveillance time interval with a maximum allowable extension not to exceed 25% of the surveillance interval, unless there is a specific SR referencing usage of the INSERVICE TESTING PROGRAM and TS SR 4.0.3 allowance to defer performance of missed inservice tests up to the duration of the specified testing frequency, and instead will require an assessment of the missed test on equipment operability.

This assessment will consider the effect on a margin of safety (equipment operability). Should the component be inoperable, the Technical Specifications provide actions to ensure that the margin of safety is protected. The proposed change also eliminates a statement that nothing in the ASME Code should be construed to supersede the requirements of any TS. The NRC has determined that statement to be incorrect. However, elimination of the statement will have no effect on plant operation or safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a Page 4 of 4

Attachment 1 Description and Assessment of Technical Specifications Changes significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Page 5 of 4

Attachment 2 Proposed Technical Specification Changes (Mark-Up)

Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATION PAGES 1-3 3/4 0-2 3/4 0-3 3/4 6-7

DEFINITIONS END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME 1.12 The END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME shall be that time interval to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker from initial movement of the associated:

a. Turbine stop valves, and

b. Turbine control valves.

This total system response time consists of two components, the instrumen-tation response time and the breaker arc suppression time. These times may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

1.13 (Deleted)

INSERVICE TESTING PROGRAM 1.14 (Deleted) 1.16a The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

HIGH (POWER) TRIP SETPOINT (HTSP) 1.15a The high power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable above 85% reactor thermal power.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

a. Leakage into collection systems, such as pump seal or valve packing leaks, that is captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE.

INTERMEDIATE (POWER) TRIP SETPOINT (ITSP) 1.16a The intermediate power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable between 65% and 85% reactor thermal power.

ISOLATION SYSTEM RESPONSE TIME 1.17 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the 1.16b channel sensor until the isolation valves travel to their required positions.

Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

LIMITING CONTROL ROD PATTERN 1.18 A LIMITING CONTROL ROD PATTERN shall be a pattern which results in the core being on a thermal hydraulic limit, i.e., operating on a limiting value for APLHGR, LHGR, OR MCPR.

LINEAR HEAT GENERATION RATE 1.19 LINEAR HEAT GENERATION RATE (LHGR) shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LIMERICK - UNIT 1 1-3 Amendment No. 66

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. 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 Limiting Condition for Operation.

Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.

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

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25%

of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operations Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements 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, & 3 components shall be applicable as follows:

a. Inservice inspection 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 Part 50, Section 50.55a. 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 Part 50, Section 50.55a.

Insert Note 1 LIMERICK - UNIT 1 3/4 0-2 Amendment No. 11,38, 125,162,169, 194

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection activities, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda for inservice testing activities, shall be applicable as follows in these Technical Specifications:

Required frequencies ASME Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities 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 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 Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities. In addition, the provision of Specification 4.0.2 are applicable to other normal and accelerated frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities.

d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.

e. Nothing in the ASME Code shall be construed to supersede the requirements of any Technical Specification.

f. The Inservice Inspection (ISI) Program for piping identified in NRC Generic Letter 88-01 shall be performed in accordance with the staff positions on schedule, methods and personnel, and sample expansion included in the Generic Letter, or in accordance with alternate measures approved by the NRC staff. Details for implementation of these requirements are included as augmented inspection requirements in the ISI Program.

LIMERICK - UNIT 1 3/4 0-3 Amendment No. 11,49, 125,171, 194

CONTAINMENT SYSTEMS MSIV LEAKAGE ALTERNATE DRAIN PATHWAY LIMITING CONDITION FOR OPERATION 3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore the pathway to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE:

a. In accordance with 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel.

Specification LIMERICK - UNIT 1 3/4 6-7 Amendment No. 71, 107

Note 1:

Inservice Inspection and Inservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

DEFINITIONS END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME 1.12 The END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME shall be that time interval to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker from initial movement of the associated:

a. Turbine stop valves, and

b. Turbine control valves.

This total system response time consists of two components, the instrumen-tation response time and the breaker arc suppression time. These times may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

1.13 (Deleted) INSERVICE TESTING PROGRAM 1.14 (Deleted) 1.16a The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

HIGH (POWER) TRIP SETPOINT (HTSP) 1.15a The high power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable above 85% reactor thermal power.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

a. Leakage into collection systems, such as pump seal or valve packing leaks, that is captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE.

INTERMEDIATE (POWER) TRIP SETPOINT (ITSP) 1.16a The intermediate power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable between 65% and 85% reactor thermal power.

ISOLATION SYSTEM RESPONSE TIME 1.17 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the 1.16b channel sensor until the isolation valves travel to their required positions.

Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

LIMITING CONTROL ROD PATTERN 1.18 A LIMITING CONTROL ROD PATTERN shall be a pattern which results in the core being on a thermal hydraulic limit, i.e., operating on a limiting value for APLHGR, LHGR, or MCPR.

LINEAR HEAT GENERATION RATE 1.19 LINEAR HEAT GENERATION RATE (LHGR) shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LIMERICK - UNIT 2 1-3 Amendment No. 48

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. 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 Limiting Condition for Operation. Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operations Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements 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, & 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Insert Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section Note 1 50.55a. 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 Part 50, Section 50.55a.

LIMERICK - UNIT 2 3/4 0-2 Amendment No. 5, 89, 124, 132, 155

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection activities, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda for inservice testing activities, shall be applicable as follows in these Technical Specifications:

Required frequencies ASME Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities 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 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 Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities. In addition, the provision of Specification 4.0.2 are applicable to other normal and accelerated frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities.

d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.

e. Nothing in the ASME Code shall be construed to supersede the requirements of any Technical Specification.

f. The Inservice Inspection (ISI) Program for piping identified in NRC Generic Letter 88-01 shall be performed in accordance with the staff positions on schedule, methods and personnel, and sample expansion included in the Generic Letter, or in accordance with alternate measures approved by the NRC staff. Details for implementation of these requirements are included as augmented inspection requirements in the ISI Program.

LIMERICK - UNIT 2 3/4 0-3 Amendment No. 12, 89, 133, 155

CONTAINMENT SYSTEMS MSIV LEAKAGE ALTERNATE DRAIN PATHWAY LIMITING CONDITION FOR OPERATION 3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore the pathway to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE:

a. In accordance with 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel.

Specification LIMERICK - UNIT 2 3/4 6-7 Amendment No. 34, 53

Note 1:

Inservice Inspection and Inservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

Attachment 3 Revised Technical Specification Bases Changes (Information Only)

Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF 39 and NPF 85 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3/4 0-3e B 3/4 0-4 B 3/4 0-6

3/4.0 APPLICABILITY SR 4.0.2 and SR 4.0.3 apply in BASES Section 6, Administrative Controls, only when invoked by a Section 6 Specification.

When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level),

the appropriate Limiting Condition for Operation is the Limiting Condition for Operation for the support system. The ACTIONs for a support system Limiting Condition for Operation adequately address the inoperabilities of that system without reliance on entering its supported system Limiting Condition for Operation. When the loss of function is the result of multiple support systems, the appropriate Limiting Condition for Operation is the Limiting Condition for Operation for the supported system.

Specification 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations 10 CFR 50.36(c)(3):

"Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that SRs must be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Surveillance time interval and allowed extension, in accordance with Specification 4.0.2, constitutes a failure to meet the Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in an OPERATIONAL CONDITION or other specified condition for which the requirements of the associated Limiting Condition for Operation are not applicable, unless otherwise specified. The SRs associated with a Special Test Exception Limiting Condition for Operation are only applicable when the Special Test Exception Limiting Condition for Operation is used as an allowable exception to the requirements of a Specification.

LIMERICK - UNIT 1 B 3/4 0-3e Amendment No. 11,162,169, Associated with Amendment No. 219

3/4.0 APPLICABILITY BASES Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveil-lance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 24-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend the surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.

Likewise, it is not the intent that REFUELING INTERVAL surveillances be performed during power operation unless it is consistent with safe plant operation. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Surveillance time interval and allowed extension. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified Surveillance time interval and allowed extension was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a Surveillance time interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering OPERATIONAL CONDITION 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to have not been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified Surveillance time interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of OPERATIONAL CONDITION changes imposed by ACTION requirements.

Failure to comply with specified Surveillance time intervals and allowed extensions for SRs is expected to be an infrequent occurrence. Use of the delay period Whenestablished by Specification a Section 6.8, 4.0.3 "Procedures and is a flexibility Programs," which specification is not intended to be states used as an operational convenience to extend Surveillance intervals.

that the provisions of SR 4.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 4.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 4.0.2 if invoked by the Section 6.8 specification).

LIMERICK - UNIT 1 B 3/4 0-4 Amendment No. 11, 38, 71, 162

3/4.0 APPLICABILITY The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR BASES referencing usage of the program.

SR(s) are not required to be performed, per Specification 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, Specification 4.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Surveillance time interval does not result in a Specification 4.0.4 restriction to changing OPERATIONAL CONDITIONS or other specified conditions of the Applicability.

However, since the Limiting Condition for Operation is not met in this instance, Specification 3.0.4 will govern any restrictions that may (or may not) apply to OPERATIONAL CONDITION or other specified condition changes. Specification 4.0.4 does not restrict changing OPERATIONAL CONDITIONS or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Surveillance time interval, provided the requirement to declare the Limiting Condition for Operation not met has been delayed in accordance with Specification 4.0.3.

The provisions of Specification 4.0.4 shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements. In addition, the provisions of Specification 4.0.4 shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in OPERATIONAL CONDITION or other specified condition in the Applicability associated with transitioning from OPERATIONAL CONDITION 1 to OPERATIONAL CONDITION 2, OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 3, and OPERATIONAL CONDITION 3 to OPERATIONAL CONDITION 4.

Specification 4.0.5 establishes the requirement that inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as required by 10 CFR 50.55a. Additionally, the Inservice Inspection Program conforms to the NRC staff positions identified in NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austinetic Stainless Steel Piping," as approved in NRC Safety Evaluations dated March 6, 1990 and October 22, 1990, or in accordance with alternate measures approved by the NRC staff.

This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.

Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Code and applicable Addenda. The requirements of Specification 4.0.4 to perform surveillance activities before entry into an OPERATIONAL CONDITION or other specified condition takes precedence over the ASME Code provision that allows pumps and valves to be tested up to one week after return to normal operation. The Technical Specification definition of OPERABLE does not allow a grace period before a component, which is not capable of performing its specified function, is declared inoperable and takes precedence over the ASME Code provision that allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

LIMERICK - UNIT 1 B 3/4 0-6 Amendment No. 11,49,169,171, 194

3/4.0 APPLICABILITY BASES When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level),

the appropriate Limiting Condition for Operation is the Limiting Condition for Operation for the support system. The ACTIONs for a support system Limiting Condition for Operation adequately address the inoperabilities of that system without reliance on entering its supported system Limiting Condition for Operation. When the loss of function is the result of multiple support systems, the appropriate Limiting Condition for Operation is the Limiting Condition for Operation for the supported system.

Specification 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations 10 CFR 50.36(c)(3):

"Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that SRs must be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Surveillance time interval and allowed extension, in accordance with Specification 4.0.2, constitutes a failure to meet the Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in an OPERATIONAL CONDITION or other specified condition for which the requirements of the associated Limiting Condition for Operation are not applicable, unless otherwise specified. The SRs associated with a Special Test Exception Limiting Condition for Operation are only applicable when the Special Test Exception Limiting Condition for Operation is used as an allowable exception to the requirements of a Specification. SR 4.0.2 and SR 4.0.3 apply in Section 6, Administrative Controls, only when invoked by a Section 6 Specification.

LIMERICK - UNIT 2 B 3/4 0-3e Amendment No. 124,132, Associated with Amendment No. 181

APPLICABILITY BASES Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 24-month surveillance interval.

It is not intended that this provision be used repeatedly as a convenience to extend the surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. Likewise, it is not the intent that REFUELING INTERVAL surveillances be performed during power operation unless it is consistent with safe plant operation. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Surveillance time interval and allowed extension. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified Surveillance time interval and allowed extension was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a Surveillance time interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering OPERATIONAL CONDITION 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, When etc.) ais discovered Section to have not and 6.8, "Procedures beenPrograms,"

performed specification when states specified, Specification 4.0.3 allows for the full delay period of up to the that the provisions of SR 4.0.3 are applicable, it permits the flexibility to specified Surveillance time interval to perform the Surveillance. However, since there is not a time interval declaring defer specified,thethe testing requirement missed not met Surveillance in accordance should be with SR performed at the first reasonable opportunity.

4.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 4.0.2 if invoked by the Section Specification 4.0.3 provides a time limit for, and allowances for the performance 6.8 specification).

of, Surveillances that become applicable as a consequence of OPERATIONAL CONDITION changes imposed by ACTION requirements.

Failure to comply with specified Surveillance time intervals and allowed extensions for SRs is expected to be an infrequent occurrence. Use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

LIMERICK - UNIT 2 B 3/4 0-4 Amendment No. 5, 34, 124

APPLICABILITY The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR BASES referencing usage of the program.

condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per Specification 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, Specification 4.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Surveillance time interval does not result in a Specification 4.0.4 restriction to changing OPERATIONAL CONDITIONS or other specified conditions of the Applicability.

However, since the Limiting Condition for Operation is not met in this instance, Specification 3.0.4 will govern any restrictions that may (or may not) apply to OPERATIONAL CONDITION or other specified condition changes. Specification 4.0.4 does not restrict changing OPERATIONAL CONDITIONS or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Surveillance time interval, provided the requirement to declare the Limiting Condition for Operation not met has been delayed in accordance with Specification 4.0.3.

The provisions of Specification 4.0.4 shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements. In addition, the provisions of Specification 4.0.4 shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in OPERATIONAL CONDITION or other specified condition in the Applicability associated with transitioning from OPERATIONAL CONDITION 1 to OPERATIONAL CONDITION 2, OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 3, and OPERATIONAL CONDITION 3 to OPERATIONAL CONDITION 4.

Specification 4.0.5 establishes the requirement that inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as required by 10 CFR 50.55a. Additionally, the Inservice Inspection Program conforms to the NRC staff positions identified in NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austinetic Stainless Steel Piping," as approved in NRC Safety Evaluations dated March 6, 1990 and October 22, 1990, or in accordance with alternate measures approved by the NRC staff.

This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.

Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Code and applicable Addenda. The requirements of Specification 4.0.4 to perform surveillance activities before entry into an OPERATIONAL CONDITION or other specified condition takes precedence over the ASME Code provision that allows pumps and valves to be tested up to one week after return to normal operation. The Technical Specification definition of OPERABLE does not allow a grace period before a component, which is not capable of performing its specified function, is declared inoperable and takes precedence over the ASME Code provision that allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

LIMERICK - UNIT 2 B 3/4 0-6 Amendment No. 132, 133, 155