Text

Proposed Tech Specs Sections 3.0 & 4.0 Re Applicability of Limiting Conditions for Operation & Surveillance Requirements,Per Generic Ltr 87-09
	ML17221A645
Person / Time
Site:	Saint Lucie
Issue date:	02/22/1988
From:	; FLORIDA POWER & LIGHT CO.
To:	;
Shared Package
ML17221A644	List: ML17221A643; ML17221A645;
References
	GL-87-09, GL-87-9, NUDOCS 8802290029
	Download: ML17221A645 (40)
	v • d • e

ATTACHMENT 1 ST. LUCIE UNIT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES 3/4 0-1 (insert) 3/4 0-2 (insert)

B3/4 0-1 (inserts)

B3/4 0-2 (inserts) 8~02>90029 Sang PDR ADOCK 05000335 PDR I

MSD.004.PLA

3 4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE RE UIREMENTS.

3 4. 0 APPLICABILITY LIMITING CONDITION FOR OPERATION Q 'Q-09 loseck cn Mh page,g 3A.4 Entry into a OPERATIONAL MODE or other specified applicability condi-tion shall not be made unless the conditions of the Limiting Condition for Operation ar et~

This provision shall not prevent passage througP PERATIONAL MODES, as .required to comply with ACTION statements.becp4h~>o h%se. 0 reqereeea~ o,res <n 4e. iadnidoch spe>~~)~ops.

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s).

subsystem(s ), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , HOT SHUTDOWN within the following 6 h'ours, and.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 MODE 5 or 6.

SURVEILLANCE RE UIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

ST. LUCIE - UNIT 1 3/4 0-1 Amendment No. 40

[CE-STS 3.0.1 Insert]

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.

[CE-STS 3.0.2 Insert]

Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation (LCO) and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

[CE-STS 3.0.3 Insert]

When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable in:

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

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

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the LCO. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

[GL 87-09 Insert to 3.04]

and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry'nto an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time.

MSD.004.PLA

APPLICABILITY SURVEILLANCE -RE UIREHENTS 4,0.2 Each Surveillance Requirement shall be performed within the specified time interval with:,

a. A maximum allowable extension not to exceed 25~ of the test inter val, and

b. A total maximum combined interval time for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified surveillance ipterval.

r. Se~Ce Sic ~.O.Sii SetOo661%l4% ~Orb W Oeb P<~e~

4.0.3 g 4.0.4 Entry into an OPERATIONAL HOOE or other specified applicability condi-tion shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise speci fied:.9iis pcovisiob she'i(n*peweA4 P~ge H radar koOPeanriogaL rretaS aS recurred fo eomg ~'i~ Aeaaw recpicemenSS,

~ ~ ~ ~ ) ~ ~ ~ ~ j ~ ~ ~ ~ ~ ~

ST. LUCI E - UNIT 1 3/4 0-2 Amendment No. g$ , 40

[CE-STS 4..03 and GL 87-09 Insert]

Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Surveillance Requirements do not have to be performed on inoperable equipment.

MSD. 004. PLA

3 4.0 APPLICABILITY BASES The specifications of this section LSl 5t Ih58't gp ~g ~ +

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PERABGC Tee.5llNfhsert f~ 3,< 4ob+~~~A 3.0.4 This speci fication<p Exceptions to this provision have been provided for a limited number of specifications when startup with inoperable equipment would not affect plant safety. These exceptions are stated in the ACTION statements of the appro-priate specifications.

ST. LUCIE - UNIT 1 B 3/4 0-1 Amendment No. 40

[Inhrai<ue'tian~* 4 ~)an Ql~.< Ayh~a&ki -e+(~IAP

$~ 5L< Ml-establish the general requirements applicable to timstinf Conditions for Operat'ion. These requirements are based on the requirementgs for Limiting Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):

"Limiting conditions for operation are the lowest functional capaabilitty or performance levels of equipment required for safe operation of the facilit . When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial'action permitted by the technical specification until the condition can be met."

5.6.i inde.rhea establishes the Applicability statement within each individual specification as the requirement for when (i.e., in which OPERATIONAL MODES or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility. The ACTION requirements establish those remedial measures that must: be taken within specified time limits when the requirements of a Limiting Condition for Operation are not met.

There are two basic types of ACTION requirements. The first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION reouirements continue to be met. The second type of ACTION requi~ement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit fs the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a MODE or condition in which the specification no longer applies. It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Surveillance Requirement when equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires the surveillance has not been completed. When a shutdown is required to if comply with ACTION reauirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable for Operation are not if the requirements of the Limiting Condition met.

f3.0 2. Ipse<~]

establishes that noncompliance with a specification exists when the reau'irements-of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (I) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completi'on of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.

pQ DTP6CI g establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.

The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown NODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to, prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the pt imary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in the COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE of operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower NODE of operation ap-plies. However, if a lower MODE of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other applicable MODE, is not reduced. For example, if HOT STANDBY is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach HOT SHUTDOWN is the next ll hours because the total time to reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to reach a lower NODE of operation in less than the total time allowed.

h The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION for one specification results in entry into a MODE or condition requirements of operation for another specification in which the requirements of the Limiting Condition Operation are not met. If the new specification becomes applicable fn lessfor time than specified, the difference may be added to the allowable limits of the second specification. However, the allowable outage outage time time of ACTION requirements for a higher NODE of operation may not be used to extendlimits the allowable outage time that is applicable when a Limiting Condition Operation is not met in a lower %DE of operation. for The shutdown requirements of Specification 3.0.3 do not apply in NODES 5 and 6, because the ACTION requirements of individual specifications define the remedial measures to be taken.

[>OH 1~~~~3 establishes limitations on MODE changes when a Limiting Condition for Uperation fs not met. It precludes placing the facility in a higher HODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in HODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher NODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an accept-able level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in .this case, entry into an OPERATIONAL BODE or other specified condition may be made fn accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

Mhen a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower HODE of operation.

APPLICABILITY BASES C, whahoc. >~ p~>g 4.0.1

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znisodsQmn wsech wramO i-bRg 4~%emPaohoae op~"r ~me~'an establish the general requirements applicabTe~to: urveillance Requirements. These requirements are based on the Surveillance Pequirements stated in the Code of Federal Reoulations, 10 CFR 50.36(c)(3):

t "Surveillance requirements are requirements relating to test, calfbra-tfon, or inspection to ensure that the necessary quality of systems and components fs maintained, that facility operation will be within safety limits, and that the limftfng conditions of operation will be met."

(N.G 'I umec~g establishes the requfrement that survefllances must be performed during tl.e OPERATIONAL NODES or other condftions for which the requirements of the Limiting Conditions for Operation apply unless otherwfse stated fn an individual Surveillance Requirement. The purpose of this speci-ffcation is to ensure that surveillances are performed to verify the, opera-tional status of systems and components and that parameters are within speci-fied lfmits to ensure safe operation of the facility when the plant is in a NODE or other specified condftfon for which the associated Limiting Conditions for Operation are applicable. Surveillance Requfrements do not have to be performed when the facility is fn an OPERATIONAL YiODE for which the requfrements'f the associated Limiting Condftfon for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception fs used as an allowable exception to the requirements of a specification.

[9.0.2. inserts) establishes the conditions under which the specified tfme interval for Surveillance Requirements may be extended. Item a. permits an allowable extension of the normal surveillance interval to facilitate surveillance schedulfng and consideration of plant operating conditions that may not be suitable for conducting the surveillance: e.g., transient conditions or other ongoing survefllance or maintenance activities. Item b. lfmfts the use of the provisions of ftem a. to ensure that ft fs not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0e2 are based on engfneerina fudgment and the recognftfon that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. These provisions are sufficient to ensure that the relfabflity ensured through surveillance activities fs not significantly deoraded beyond that obtained from the specfffed,surveillance interval.

establishes the failure to perform a Surveillance

~equ rement within the allowed sur veiiiance interva1, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point fn time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0e3. However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action.

If the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown is required to comply with ACTION requirements, e.g.,

Specification 3.0.3, a 24-hour allowance is provided to permit a delay fn implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION reauirements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance Requirements .that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limit's of the ACTION requirements are applicable at the time that the surveillance is terminated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

[0 O.H Ensaig establishes the requirement that all applicable surveillances must 6e met before entry tnto an OPERATIOKAL NODE or other condktfon of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plart startup or following a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.

ATTACHMENT 2 ST. LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES 3/4 0-1 3/4 0-2 B3/4 0-1 (inserts)

B3/4 0-2 (inserts)

B3/4 0-3 (inserts)

MSD. 004. PLA

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE RE UIREMENTS 3/4. 0 APPLICABILITY LIMITING CONDITION FOR OPERATION 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 to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and/or associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it,'as applicable, in:

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

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

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

m4 3.0. 4 Entry into an OPERATIONAL MODE or other specified condition shall not the conditions of the Limiting Condition for Operation are met be made unless haloed This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION "statements. Exceptions to these requirements are stated in the individual specifications.

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ST. LUCIE - UNIT 2 3/4 0"1

APPLICABILITY SURVEILLANCE RE UIREMENTS 4.0.1 Surveillance, Requirements shall be applicable during the OPERATIONAL MOOES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

C 4.0.2 Each Surveillance Requirement shall be performed within the specified

~J O time interval with:

a. A maximum allowable extension not to exceed 25X of the surveillance K$ gg interval, and

+4:~g b. The combined time interval for

'he any 3 consecutive surveillance intervals e 3.25 times the s cified surveillance in

~@~ Wf~ ~9,4.

~g 4.0.3 ailure to perform a ur e> ance equirement within the~

intervaQ shall constitute OPERABILITY requirements for a Vl M Limiting ondition -for Op ration.

v)W Surveillance Requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.%a p'6x~sioh Spab ada pe<ek~~e,kg~5'4

~'RNlMALWDeS aS K(gled kocoaPq vip PFtiN reqNt gB g P4 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

~g~) g 8 Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing ASME Code Class 1, 2 and 3 pumps and valves 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, g.elk~ Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

ST. LUCIE - UNIT 2 3/4 0-2

3/4. 0 APPLICABILITY BASES The specifications of this section<

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e-fA-W ponens-4PKRAB46-and-(-b$ -alA Exceptions to this specification have been provided for a limited number of specifications when startup with inoperable equipment would not affect plant safety. These exceptions are stated in the ACTION statements of the appropriate specifications.

ST. LUCIE - UNIT 2 8 3/4 0-1

rod 'ton @sa Kelbon JJR.G 4(f)icaklik~ -b0$ +Qnci)loaaak<piHuid4) fmuv SLY @)

establish the general requirements applicable for Operation. These requirements are based on the t 0 Lim itinq Conditions ~

the Code of requirements for Limiting Conditions for Operation stated in Federal Regulations, 10 CFR 50.36(c)(2):

"Limiting conditions for operation are the lowestoperation functional capability of the or performance levels of equipment required for safeof a nuclear reactor is not facility. When a limiting condition for operation met, the licensee shall shut down the reactor or follow any remedial action can be met."

permitted by the technical specification until the condition

'3.0 3 jose&,

establishes the Applicability statement within each lndSvfdual s~cTfScatSon as the requSrement for when (S.e., fn which OPERATIONAL NODES or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility. The ACTION requirements establish those remedial measures that must be taken within specified time limits when the requirements of a Limiting Condition for Operation are not met.

There are two basic types of ACTION requirements. The first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION reouirements continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a NODE or condition in which the specification no longer applies. It fs not intended that the shutdown ACTION require'ments be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Surveillance Requirement when equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. Nen a shutdown is required to comply with ACTION reauirements, the plant may have entered a NODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new sp6cification becomes applicable if the requirements -of the Limiting Condition for Operation are not met.

establishes that noncompliance with a specification exists when the reouirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The pur pose of this specification is to clarify that (I) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completi'on of the remedial measures of the ACTION requirements is not required when comp1iance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.

C establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.

The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction fn electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The-time limits specified to reach lower NODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility 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.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the plant to be in the COLD SHUTDOWN HOflE when a shutdown is required during the POWER NODE of operation. If the plant is in a lower HOVE of'peration when a shutdown is required, the time limit for reaching the next lower YODE of operation ap-plies. However, if a lower NODE of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other applicable MODE, is not reduced. for example, if HOT STANDBY fs reached fn 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach HOT SHUTDOWN is the next II hours because the total time to reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to reach a lower NDE of operation in less than the total time allowed.

/

(S.oe ~nseA C 4~ueh)

The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one

, specification results fn entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable fn less time than specified. the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 do not apply fn MODES 5 and 6, because the ACTION requirements of individual specifications define the remedial measures to be taken.

[3.GA inset establishes limitations on MODE changes when a Limiting Condition ~or peration fs not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an accept-able level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in .this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility fn a lower MODE of operation.

'le BASES c ~> pew gal).+ onh~t~a . f~Q.'Q4$ AME f4'.0.l CA Qf~p 6 4.0. 1 This specification

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'A~spaf'~et)i~he <0 6> seh.ia~ establish the general requirements app >ca e to urve ance equ rements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Reoulations, 10 CFR 50.36(c)(3):

"Surveillance requirements are requirements relating to test, calibra-tion, 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."

I ~p. establishes the requirement that surveillances must be PPEEAIIPIML Adtpp tl dttt I II t requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this speci-A fication is to ensure that surveillances are performed to verify the opera-tional status of systems and components and that parameters are within speci-fied limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the reoufrements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Pg.b.Z. st,meth/

establishes the conditions under which the specified time Etf t t t dd. It allowable extension of the normal survei11ance interval to facilitate

.p ft 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. Item b. limits the use of the provisions of item a. to ensure that it fs not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are based on engineering iudgment and the recognition that the most probable result of, any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. These provisions are sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

LghQ lass" t 5 estahiishes the ra<'lore to perforn a Surve111aooe provisions by the Requirement with)n the allowed surveillance interval, defined failure to meet the of Specification 4.0.2, as a condition that constitutes a OPERABILITY requirements for a Limiting Condition for Operation. Under the provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3. However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action.

If the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown is required to comply with ACTION requirements, e.g.,

Specification 3.0.3, a 24-hour allowance is p~ovided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION reoufrements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit .for the completion of Surveillance Requirements that become applicable as a consequence of NODE changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If a surveillance is not completed within the 2<-hour allowance, the time limits of the ACTION requirements are applicahle at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time that the surveillance is terminated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

Ho~ever, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

I ~

BASES 4.0.4 This specification p~ glgl ~N esec4 N< 4.D.g on ~<4 qacgQ 0

4.0.5 This specification ensures 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 will be performed in accordance with a periodically update8 version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda'-

as required by 10 CFR 50.55a. Relief from any of the above requirements has been provided in writing by the Commission and is not a part of these Technical Specifications. '

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. This clarification is provided to ensure consistency in surveillance intervals throughout these 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 Boiler and Pressure Vessel Code and applicable Addenda. For example, the requirements of Specification 4.0.4 to perform surveillance activities prior to entry into an OPERATIONAL HOOE or other specified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested up to one week. after return to normal operation. And for example, the Technical Specification definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified function is declared inoperable and takes 'precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before being declared inoper&le.

ST. LUCIE - UNIT 2 B 3/4 0-3 Amendment No.25

7 n

establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as star tup.

Under the provisions of this specification, the appli'cable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limitino Conditions for Operation are met during initial plart star tup or following a plant outage.

@hen a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.

ATTACHMENT 3 Discussion on Pro osed License Amendment The purpose of the proposed license amendments is to:

1) upgrade portions of the St. Lucie Unit 1 Technical Specifications, Sections 3.0 and 4.0, Applicability Requirements of Limiting Conditions for Operation (LCO) and Surveillance Requirements, to read as the Combustion Engineering Standard Technical Specifications (CE-STS), NUREG 0212, Revision 2 and

2) incorporate changes to Sections 3.0 and 4.0 of the St.

Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications by Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications on the Applicability of Limiting Conditions for Operation and Surveillance Requirements."

St. Lucie Unit 1 Limitin Conditions for 0 eration LCO 3.0.1 3.0.2 and 3.03 A change is proposed to LCO Applicability Statements 3.0.1, 3.0.2, and 3.0.3 incorporating the CE-STS wording for compliance with LCOs and ACTION requirements. The intent of the LCO applicability statements is not being changed. The change to the CE-STS wording results in improved statements of applicability.

Limitin Condition for 0 eration 3.0.4.

A change is proposed to LCO Applicability statement 3.0.4 incorporating conclusions reached in Generic Letter 87-09. As discussed in the Generic Letter, Technical Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements. This is consistent with NRC's regulatory requirements for an LCO. The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required.

MSD.004.PLA

Surveillance Re irements 4.0.3 A change is proposed to Surveillance Requirement 4.0.3 incorporating the CE-STS wording for surveillance requirement performance. Also, a change is proposed incorporating conclusions reached in Generic Letter 87-09. As discussed in the generic letter, it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The opposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are operable. When a surveillance is missed, primarily a question of operability that has not been verified it is by the performance of the required surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the TS should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance.

After reviewing possible limits, the staff has concluded that, based on these considerations, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.

Surveillance Re irements - 4.0.4 A change is proposed to Surveillance Requirement 4.0.4 incorporating conclusions reached in Generic Letter 87-09. As discussed in the generic letter, the potential for a plant upset and challenge to safety systems is heightened if are performed during a shutdown to comply with Action surveillances Requirements. It is not the intent of Specification 4.0.4. to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements. Accordingly, Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. Also, a change has been made deleting I

the paragraph which discusses the provisions of MSD.004 ~ PLA

Specification 4.0.4 not being applicable to the performance of certain fire protection technical specifications until the completion of the initial surveillance interval associated with each specification. The initial surveillance intervals have been completed for these specifications, therefore, this paragraph is deleted.

3 4.0 A licabilit Bases A change is proposed to Applicability Bases 3.0.1,3.0.2, 3.0.3, 3.0.4, 4.0.1, 4.0.2, 4.0.3 and 4.0.4 incorporating conclusions reached in Generic Letter 87-09.

St. Lucie Unit 2 Limitin Condition for 0 eration 3.0.4 A change is proposed to LCO Applicability Statement 3.0.4 incorporating conclusions reached in Generic Letter 87-09. As discussed in the generic letter, Technical Specification 3.0.4.

unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements. This is consistent with NCR's regulatory requirements for an LCO. The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements establish a specified time interval.

in which the LCO must be met or a shutdown of the facility would be required.

Surveillance Re irements 4.0.3 A change is proposed incorporating conclusions reached in Generic Letter 87-09. As discussed in the generic letter, it conservative to assume that systems or components are inoperable is overly when a surveillance requirement has not been performed. The opposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are operable.

When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of the required surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance a before time shutdown limit that requirements may apply, the TS should include would allow a delay of the required actions to permit the

. performance of the missed surveillance.

MSD. 004. PLA

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance.

After reviewing possible limits, the staff has concluded that, based on these considerations, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.

Surveillance Re irements 4.0.4 A change is proposed to Surveillance Requirement 4.0.4 incorporating conclusions reached in Generic Letter 87-09. As discussed in the generic letter, the potential for a plant upset and challenge to safety systems is heightened are performed during a shutdown to comply with Action if surveillances Requirements. It is not the intent of Specification 4.0.4 to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements. Accordingly, Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements.

3 4.0 A licabilit - B ses A change is proposed to Applicability -Bases 3.0.1, 3.0.2, 3.0.3, 3.0.4, 4.0.1, 4.0.2, 4.0.3 and 4.0.4 incorporating conclusions reached in Generic Letter 87-09.

MSD.004 'LA

Pl Jl

pv v ATTACHMENT 4 No Si nificant Hazards Consideratio The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission s regulations, 10 CFR 50.92, which states that no significant hazards considerations are involved the operation of the facility in accordance with the proposed if amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated or(3) involve a significant reduction in a margin of safety. Each standard is discussed as follows:

(1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

For the changes intended to achieve consistency with the recommendations of Generic Letter 87-09 "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," the Staff has previously evaluated these changes in the generic letter and determined that the modifications will result in improved technical specifications.

Specification 3.0 ' unduly restricts facility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation. For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into'n operational mode or other specified condition of operation should be permitted in accordance with those ACTION requirements. This is consistent with the NRC s regulatory requirements for an LCO.

It is overly conservative components are inoperable to assume that systems or when a surveillance requirement has not been performed. A 24-hour time limit has been included in Specification 4.0.3 allowing a delay of the required actions to permit the performance of the missed surveillance. The NRC has concluded that the 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset I

and challenge to safety systems when the alternative is a MSD.004.PLA

shutdown to comply with ACTION requirements before the surveillance can be completed.

The NRC has concluded that the potential for a plant upset and challenge surveillances are to safety systems is heightened if performed during a shutdown to comply with ACTION requirements. Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

For the changes intended to achieve consistency with the Combustion Engineering Standard Technical Specifications (CE-STS), the intent of the Specifications will not be changed nor will operating limitations of the Technical Specifications be changed.

Therefore, the proposed changes will not significantly affect the probability or consequences of accidents previously analyzed.

(2) Use of the modified specification would not create the possibility of a new. or different kind of accident from any accident previously evaluated.

The changes being proposed by FPL to achieve consistency with Generic Letter 87-09 and the CE-STS will not lead to material procedure changes or to physical modifications..

Therefore, the proposed changes do not create the possibility of a new or different kind of accident.

(3) Use of the modified specification would not involve a significant reduction in a margin of safety.

For the changes intended to achieve consistency with the recommendations of Generic Letter 87-09 "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements,>> the Staff has previously evaluated these changes in the generic letter and determined that the modifications will result in improved technical specifications.

Specification 3.0.4 unduly restricts facility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation. For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those ACTION requirements. This is consistent with the NRC's regulatory I

requirements for an LCO.

MSD.004.PLA

It is overly conservative components are inoperable to when a assume that systems or surveillance requirement has not been performed. A 24-hour time limit has been included in Specification 4.0.3 allowing a delay of the required actions to permit the performance of the missed surveillance. The NRC has concluded that the 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with ACTION requirements before the surveillance can be completed.

The NRC has concluded that the potential or a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with ACTION requirements.. Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

For the changes intended to achieve consistency with the Combustion Engineering Standard Technical Specifications (CE-STS), the intent of the Specifications will not be changed nor will operating limitations of the Technical Specifications be changed.

Therefore, use of the modified specification would not involve a significant reduction in the margin of safety.

Based on the above, we have determined that the amendment request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

MSD. 004. PLA

a e'

ML17221A645

Text

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