Text

Summary of 940614 Meeting W/Util to Discuss Plant Plans to Submit TS Amend Request to Replace Current Customized TS W/Std Ts.List of Attendees in Encl 1
	ML18059B119
Person / Time
Site:	Palisades
Issue date:	07/20/1994
From:	Hsia A; Office of Nuclear Reactor Regulation
To:	; Office of Nuclear Reactor Regulation
References
	NUDOCS 9407280067
	Download: ML18059B119 (49)
	v • d • e

.*

July 20, 1994 Docket No. 50-255 LICENSEE:

Consumers Power Company FACILITY:

Palisades Nuclear Generating Plant

SUBJECT:

SUMMARY

OF MEETING HELD ON JUNE 14, 1994 On June 14, 1994, members of the NRC staff met with representatives of Consumers Power Company (CPCo) to discuss Palisades' plans to submit a technical specification (TS) amendment request to replace the current customized TS with the standard TS (STS). lists the meeting attendees. is the meeting agenda used. is a copy of the Palisades comments on Combustion Engineering's restructured TS.

Enclosure 4 is a copy of examples of the draft STS.

The meeting discussions included the following topics:

The general approach of submitting the TS amendment request.

Each submittal will consist of several TS chapters, but a final submittal for approval will encompass all the previously submitted chapters.

For each chapter, a submittal will contain:

the proposed pages the no *significant haza~ds analysis the differences between the proposed and existing TS the marked-up pages of NUREG-1432

Proposed schedule.

The first submittal is expected in September 1994 and the approval is expected late 1996.

The licensee plans to send a letter to the NRC documenting their commitment of converting the current TS to the STS.

Enclosures:

1.

Meeting attendees

2.

Meeting agenda

3.

Comments on CE restructured TS

4.

Examples of proposed STS *

OFFICE Original siQned by

' A~thony H. Hsia, Project Man~ger

'Project Directorate 111~1 DivisiOn* of Reactor Projects.- III/IV Office. o~ Nu~l~ar~Reactor ~~guJation

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Consum*ers Power Company cc:

Mr. Thomas J. Palmisano Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Mr. David W. Rogers Plant Safety and Licensing Director Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Comp~ny 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacbn, Esquir~

Consumers Power Company 212 West Michigan Avenue Jackson; Michigan 49201 Regional Administrator, Re~ion III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Rotim 1 - Capitol Building Lansing, Michigan 48913 U.S. Nuclear Regulatory Commission Reside~t Inspector Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N. Logan Street P. 0. Box 30195 Lansing, Michigan 48909 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.

Washington DC 20037 Alora Davis Commitment Tracking System Coordinator Palisades Plant Consumers Power Company 27780 Blue Star.Memorial Hwy.

Covert, Michigan 49043-9530 Mr. Robert A. Fenech Vice President, Nuclear Operations Consumers Power Company Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 April 1994

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ENCLOSURE 1 MEETING BETWEEN NRC AND CONSUMERS POWER COMPANY REGARDING PALISADES TECHNICAL SPECIFICATIONS David Rogers Barry Young Chris Grimes Bob Tjader Nanette Gi 11 es Anthony Hsia June 14, 1994 ORGANIZATION CPCo/Safety & Licensing CPCo/licensing NRR/OTSB NRR/OTSB NRR/OTSB NRR/DRPW

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NRR-OTSB/CPCo STS meet;ng

--1-} Meeting @ 1 White fljnt 1:00 PM June 14, 1994

2) Expected attendees:

Barry Young, Dave Rogers, Mike Parker, Tony Hs;a, Chris Grimes 3} Submittal timing:

a} any preferred sequence?

b) Proposed:

1.0, 3.0, 5.0 as a foundation 3.3, 3.5, 3.8 as mostly format changes 3.6, 3.7 as major procedure work here 2.0, 3.1, 3.2 3.4, 3.9, 4.0 c) hold certain chapters for SD Risk rulemak;ng?

d) can project be completed soon enough to be useful?

first submittal 9/94 final submittal 12/95 ap.prov a 1 9/96

mplementation 3/97

4) Co-ord;nation with pending TSCRs a} TSCRS in the works

1) SOC, l&C, COLR; already submitted

2) P/T curves; need prior to 95 REFOUT

3) TSP; need for 95 REFOUT

4) HTP correlation need for 95 REFOUT

5) ECCS upgrade; ready for submittal, desire clarification of TS

6) 3% RV as found.allowance, cost Benefit

7) Admin upgrade, cost benefit

8) Electrical; convnitted for 9/1/94 submittal.

b) How to avoid duplicate preparation & review time?

. 5) OTSB assistance needed to write proposed TS a) Bulletin Board or copies of approved revisions to NUREG 1432 b) contact for questions such as:

What is desired location of fuel oil quality SRs 3.8 or 5.0?

Might minor changes to section 1.3 be acceptable?

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ENCLOSURE 2

COMMENTS ~CE RESTRUCTURED TECHNICAL SPEC~CATIONS ENCLOSURE 3 "comments.sts"

--1-.

Technical issues A.

8.

c.

D.

L

f.

G.

H.

B.N. Young lCO 3.0.3 is the only LCO or SR in section 3.0 which contains an applicability statement.

The way the existing statement is worded, it raises the question "when are the.others applicable?

I suggest changing the subject wording to:

"LCD 3.0.3 is only applicable in MODES 1, 2, 3, and 4." or possibly to: "LCO 3.0.3 is not applicable in MODES 5 or 6.". The statement "LCO 3.0.3 is applicable in MODES 1, 2, 3, and 4." does not actually provide any information about its applicability in Modes 5 or 6.

Certainly it implies that LCO 3.0.3 is not applicable in those Modes, but it would be more explicit if the word "only" was added or if the negative form was used.

LCD 3.1.1 (Shutdown Margin, Modes 3 & 4):

If boration to restore SOM cannot be accomplished, a 3.0.3 entry would impose a cooldown requirement.

In this situation, a cooldown would further aggravate the problem of insufficient SOM.

LCD 3.1.5 (CEA-Control Rod Alignment): The definition of "Group Position" is unclear, each CEA position is measured, and the position of the selected CEA is displayed.

It is possible to have the positions of two CEAs in a group differ by more than [15] inches, but, unless all CEAs in a group but one.were at the same position, it would be difficult to say where the "group" itself was.

as an example, if one CEA in a group was at 100 inches, two* at 116 inches, and the balance in between, Condition A would certainly apply, but it is unclear as to whether Condition E would apply.

In short, there is really no such thing as**

group position, and it should not be referenced.

The group position used for the PDIL (LCO 3.1.7) is simply the position of the selected, or "target" CEA.

The CEA position deviation alarm assures that the operators are alerted if the extreme spread between positions within a group exceed the alarm setpoint. The analysis assume that the rods are inserted below the PDIL by the distance used for the deviation setpoint.

Part Length Rod positioning is not addressed by the Analog section 3.1, or any other section.

SR 3.3.11.2 (Channel Calibration for PAM Inst), needs a note stating that "Neutron detectors are excluded from CHANNEL CALIBRATION."

LCO 3.4.10 (Pressurizer Safeties) and 3.7.1 (Secondary Safties): Does the stated applicability agree with the B&PV code requirem~nts?

SR 3.4.10.1 (Pressurizer Safty testing): The statement that "Following teJting, lift settings shall be within +/- 1%." is unclear.

Does this mean that they may be outside the specified band by 1%?

(In this case the required settings could then be stated to be 2500 psia +/- 2%.)

This same statement is made in SR 3.7.1.1, where the valve settings are individually stated, and it therefore is more precise. The statement, in either case should state to what the percentage applies.

I suggest that in each case either 1) the settings be specified for each valve (or group of valves with the same requirements) and the subject statement be extended to read: "Following testing, lift settings shall be within

+/- 1% of the required setting.", or 2) an allowable band be stated for each valve (or group of valves having the same requirements).

LCO 3.4.12 (LTOP): Conditions E (1 PORV inop in Mode 4) and F (1 PORV inop in~;,

i'){o~'/2 Page 1

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B.N. Young e

COMMENTS ON CE RESTRUCTURED TECHNICAL SPECIFICATIONS Mode 5) are differentiated by Mode.

The guidance given in the follow up letters to GL 90-06 states that the intended differentiation was whether there was a bubble in the pressurizer-or not.

LCO 3.4.12 (LTOP): There are no SRs for the cycling of PORVs and Block valves as required by GL 90-06.

LCO 3.6.3 (Cont Isolation Valves), Required Action E.3 (Perform purge valve testing SR):

This test is difficult or impossible to perform during operation.

if the inner valve is leaking, the outer valve can only be tested by installing a blind flange inside the containment.

In our plant, that cannot be accomplished at power.

If the outer valve is leaking, there is no qualified valve or piping down stream to allow testing of the inner valve.

LCO 3.6.4 (Cont pressure), completion time for Action A.1 (Pressure not w/in limit): This time should be 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , as for LCO 3.6.5, Action A.1 (Cont temp not w/in limit). The associated Condition, pressure not within limits, occurs most often due to containment temperature increases.

The proper correction is to reduce temperature, not necessarily to vent the containment.

As recognized in LCO 3.6.5, temperature excursions cannot be corrected quickly.

Since the safety impact is similar, for either temperature or pressure (or both) being above the limit, I suggest that both c~mpletion times be 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

This problem is more apparent at plants which do not credit automatic closure of the purge valves, and therefore do not open them when containment integrity is required.

LCO 3.7.2 (MSIVs): The term "deactivated", used in the applicability, is not explained in the bases.

It is not clear how to apply this term to differ~nt kinds of MSIV actuators.

LCO 3.7.3 (MFIVs): The term "deactivated", used in the applicability, is not explained in the bases.

It is not clear how to apply this term to different sorts of MFIV actuators..

LCO 3.7.14 (Fuel Bldg Air Cleanup Sys):

It appears that a "LCOs 3.o.3*and 3.0.4 afe not applicable" note would be appropriate for this LCO (at least for plants who do not use the MODE 1, 2, 3, and 4 applicability) because Plant operating conditions neither add to nor detract from the effects of a fuel handling accident in the fuel storage building.

LCO 3.7.16 (Fuel Pool Water Lvl):

It appears that a "LCO 3.0.4 is not applicable" note would be appropriate for this L~O because Plant operating conditions neither add to nor detract from the effects of a fuel handling accident in the fuel storage building.

LCO 3.7.17 (Fuel Pool Boron):

It appears that a "LCO 3.0.4 is not applicable" note would be appropriate for this LCO because Plant operating conditions neither add to nor detract from the effects of an inadvertent.criticality accident in the fuel storage building.

LCO 3.7.18 (Fuel Stroage): It appears that a "LCO 3.0.4 is not applicable" note would be appropriate for this LCO because Plant operating conditions neither add to nor detract from the effects of an inadvertent criticality accident in the fuel storage building.

SR 3.8.2.1 (SR list for AC sources-Shutdown): This SR statement excepts two LCO Page 2 06/01/94

COMMENTS ON CE RESTRUCTURED TECHNICAL SPEC..,,,.ICATIONS 3.8.1 SRs and also has a note which states that a long list of LCO 3.8.1 SRs are not required.

I find this confusing.

Is there some difference intended from simply stating which 3.8.1 SRs are required (as is done for LCO 3.5.3)?* There are 13 out of 20 which are not required, making it shorter as well as clearer to list those which are r*equired.

S.

SR 3.8.2.1: The 3.8.1 SRs which are required (those not excepted) both include SRs which I would not expect to be required, and exclude SRs which I would expect to be required.

The selection of those SRs which are required is judgmental, but since there is a chance that the list is not what was intended, I will list my observations.

1.

SR 3.8.1.3 (60 min load test) is excepted when the ability to carry a load is just as important for an operable DG whether cold or hot.

2.

SR 3.8.1.7 (10 sec. start) is included, when no spe~ific credit is taken for any particular starting time.

Would not 12 seconds or 22.8 seconds be just as good, as far as analysis is concerned?

What is the basis for 10 seconds when cold? With the RCS cold, there is plenty of time for manual starting and loading of necessary equipment.

3.

SR 3.8.1.12 (Starting & loading on an ESF signal w/o LOSP) is required..

Most ESF signals, however are not required to be operable under these conditions.

4.

SR 3.8.1.14 (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months load test) is excepted when the ability to carry a load is just as important for an operable DG whether cold or hot.

5.

SR 3.8.1.16 (Transfer of load from DG to Offsite) is excepted, but se~ms just as important cold or hot.

T.

SR 3.8.4.8 (60 month Battery capacity test) requires annual testing of old or degraded batteries. This would require an extra plant shutdown for most units.

That seems contrary to the overall safety goal.

I suggest an 18 month frequency unless there is analytical, rather than judgmental, basis for the annual testing.

. U.

SR 3.8.5.1 (SR list for DC sources-Shutdown}: This SR, like SR 3.8.2.1, is confusing in that it gives a list of applicable SRs from 3.8.4, and a different list of 3.8.4 SRs which are not required.

If this. treatment is supposed to convey something other than a list of required SRs, it needs to be explained,

. otherwise just list the 3.8.4 SRs which are required as is done in LCO 3.5.3.

V.

SR 3.8.6.2 (Cell Parameters):

The two special requirements in the frequency column seem to use similar terms differently.

B.N. Young In my experience, the idea of a *battery discharge < [110] V" clearly implies an event where the battery became sufficiently discharged that its no load terminal voltage dropped below 110 Volts.

Applying that idea to a "battery overcharge > [150] V" implies that a battery can be overcharged sufficiently to raise its no load terminal voltage significantly above its full charge value.

I do not believe that to be true.

Experience with automobile and submarine batteries tells me that a continued over charge prod~ces excessive gassing and heating, and electrolyte loss, but Page 3 06/01/94

, *i COMMENTS.E RESTRUCTURED TECHNICAL SPEC.CATIONS that it is physically impossible to continue to raise the potential between the plates once the chemical process has been driven to completion.

Is the "battery overcharge > (150] V" possibly referring to the bus voltage exceeding 150 Volt~

during a charge, thereby being a limit on the charging rate?

W.

LCO 3.9.2 (Source Range Monitors}, Conditions A (1 SRM inop) and B (2 SRM inop) should have the word "required" inserted before "SRM".

Several plants have four channels of SRMs and could, therefore, have both two SRMs operable (thus meeting the LCO) and two SRMs inoperable (thus having Conditions A and B apply).

X.

LCOs 3.1.4 (HTC}, 3.4.2 CTavg when critical}, 3.4.4 (RCS Loops, MODES 1 & 2*}

and 3.7.19 (Secondary Activity} provide only a shutdown Action.

In those cases where a "Restore" Action is to be an option, the Required Actions * (in 3.4.2 for example} need to be:

A.I Restore Tave to within limits.

OR A.2 Be in MODE 3.

Otherwise the entry into such a Condition can be construed to be reportable under IO CFR 50.72 as "a shutdown required by Tech Specs". A similar situation occurred at Palisades, where the LCO compliance was restored almost immediately and well prior to the termination of the completion time.

A shutdown was not initiated, however, our Resident Inspector felt strongly that the event was reportable.

The fact that an actual shutdown was not initiated, in our case, did not sway the issue.

II. Comments on LCO 3.4.I4 (PIV Leakage):

A.

LCO Actions Note I:

The note allows separate Condition entry for each flow path, rather than for each PIV.

It appears that this wording may have been chosen to allow the Actions to apply multiple leaking PIVs in different flow paths, but to disallow multiple leaking PIVs in the same flow path.

If that is so it is far to subtle.

if not, why not use the simpler wording "Separate Condition entry is allowed for each PIV." and. let the RCS operational leakage LCO apply if there is* actual flow through the path?

B.

LCO Actions Note 2:

Note 2, according to its basis comments, was included in case the leakage through a PIV make another required system or component inoperable.

It is much more likely that the system or component would be made inoperable by Required

.Action A.I, A.2, or C.I.

C.

Note for Required Action A.I & A.2:

The words "on the RCS pressure boundary" are unclear to me.

I suggest that they B.N. Young Page 4 06/0I/94

e e

COMMENTS ON CE RESTRUCTURED TECHNICAL SPECIFICATIONS be changed to 11within the RCS pressure boundary" (as was done in the basis) or to (my own preference) "in the high pressure portion of the piping".

0.

Actions A.I, A.2 (the first), and C.I:

The use of the term "automatic valve" is unclear.

Is this intended to mean a valve which is actuated by an automatic signal, such as a safety injection motor operated valve or a containment isolation valve; or is it intended to mean a power operated valve, whether actuated automatically or actuated manually by remote means, such as a shutdown cooling suction valve?

E.

Actions A. I and A.2 I.

During the plant conditions under which this LCO is applicable, the loop check valves and HPSI or LPSI valves are closed, as are both SOC suction valves. Therefore Action A.I is normally automatically completed if any one of these PIVs were found to be leaking (with the exception of deactivating a SOC suction valve if the other should be leaking).

2.

The deactivation of ECCS or SOC motor operated valves is, in my o.pinion, contrary to safety.

The ECCS automatic valves typically open to admit cooling fluid in response to a low pressure signal; the low pressure condition would eliminate or reduce the concern for a leaking PIV.

The requirement to deactivate a SOC suction valve (if these are included in the intended class of automatic valves) also seems imprudent,.as discussed in F.3 below, with respect to Action C.l.

F.

tondition C & Action C.I:

1.

Condition C refers to equipment which is not required by the LCO.

There appears to be no reason to enter the Condition, whether the* interlock.

works or not (LCO 3.0.2 requires complying with Required Actions only when the LCO is not met).

The SOC interlock is related to PIV leakage.

only by the general function of preventing overpressurization of low pressure piping; it is evident that the interlock Actions were added to the PIV LCO simply because they fit no where else.

Do these interlocks fit any of the criterion for inclusion? If the interlock requirements are to be retained, the LCO needs to be modified.

2.

The part of the interlock which closes the valves automatically is of questionable desirability; it might avoid a potential overpressurization, but it provides an opportunity for a loss of decay heat removal.

It is difficult to believe that these valves (typically motor operated) could close quickly enough to protect against a pressure transient. Such protection is part of the lTOP design, at least for the Palisades unit.

3.. The requirement to isolate the affected penetration should certainly not be effective during SOC operations, where it would guarantee a loss of decay heat removal.

The requirement to deactivate the SOC system, for want of this interlock, seems imprudent under any conditions.

The SOC system is needed, as the final heat removal system, following all normal shutdowns and following all but post LOCA emergency shutdowns.

G

SR 3

4

14

1 B.N. Young Page 5 06/01/94

1.

2.

3.

4.

COMMENTS O.E RESTRUCTURED TECHNICAL SPECI.ATia°NS Note 2:

This note is not needed; it restates what is already contained in the Applicability statement.

SR wording:

While there has been an effort to limit the numbers of tables in the Tech Specs, it might be desirable to utilize a table of valves and their leakage limit for this LCO & SR.

SR 3.4.14.1, Frequency (the second):

Change to the more standard wording

{eliminating the redundant words) "Prior to MODE 2 entry when the unit has been in MODE 5 for ~ 7 days in not performed within 9 months" SR 3.4.14.1, Frequency (the second):

a.

I believe that "action" in the 5~ line was intended to be "actuation".

b.

Testing a PIV requires a containment entry at some plants; testing

at power may not be possible.

The test following each use requirement should apply only when such testing would not require a shutdown.

In addition, testing may make an associated system inoperable, so that testing following each use may cause an increase in risk rather tha_n a decrease.

III. Consistency issues:

A.

Listing of Definitions:

Ten definitions provide abbreviations or symbols~ Nine are in the form "NAME (symbol)", and are alphabetized by name.

One (E) is in the form "Symbol - -

NAME", and is alphabetized by the symbol.

They should all be alphabetized by name, and be in the s~me form.

B.

There are several variants of each ~f the typical notes used in an SR box:

B.N. Young

.}.

SRs not required to be performed prior to...

a.

SR 3.1.3-.1 (Verify core reactivity): "This Surveillance is not required to be performed prior to entry into MODE 2."

b.

SR 3.1.4.1 (Verify MTC): "This Surveillance is not required to be perfo~med prior to entry into MODE 2."

c.

SR 3.1.4.2 (Verify MTC): "This Surveillance is not required to be performed prior to entry into MODE 1 or 2."

d.

SR 3.1.7.1 (Verify CEA group position): "This Surveillance is not required to be performed prior to entry into MODE 2."

e.

SR 3.2.1.2 (Verify incore alarm setpoints): "Not required to be performed below 20% RTP." *

.f.

SR 3.2.1.3 (Verify Incore Alarm setpoints): "Not required to be performed below 20% RTP."

Page 6 06/01/94

B.N. Young COMMENTS O~E RESTRUCTURED TECHNICAL SPECl~ATIONS I suggest deleting the "This Surveillance is" of 3.1.3.1, 3.1.4.1, 3.1.4.2, and 3.1.7.1, and replacing the "below" of 3.2.1.2 and 3.2.1.3 with. the"<" symbol.

2.

SRs not required to be performed until.

a.

Example 1.4-3: "Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .after~

25% RTP.

b.

SR 3.3.1.2 (Calorimetric): "Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is~ [20]% RTP."

c.

SR 3.3.1.3 (Monthly Excore Cal): "Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is~ [20]% RTP.

11

d.

SR 3.4.1.4 (Flow determination using heat balance): "Not required to be performed until [24] hours after~ [90]% RTP."

e.

SR 3.4.13.1 (RCS Inventory): "Not Required to be performed in MODE 3 or 4 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of steady state operation."

(There is also a similar note in the frequency column. Are both necessary?)

f.

SR 3.4.16.3 (Determine E): "Not required to be p~rformed until 31 days after.

I *suggest deleting the "THERMAL' POWER IS" of 3.. 3.1.2 and 3.3.1.3, since it is easily inferred and usage would then follow the example of section 1.4.

3.

SRs only required under special conditions:

a.

b.

c.

d.

e.

f.

g.

h.

SR 3.2.1.l (Verify ASI alarm setpoints): "Only applicable when the Excore Detector Monitoring System is being used to determine LHR.

SR 3.2.1.2 (Verify Incore setpoints): "Only applicable when the Incore Detector Monitoring System is being used to determine LHR.

SR 3.2.1.3 (Verify lncore setpoints.): "Only applicable when the Incore Detector Monitoring System is being used to determine LHR.

SR 3.4.I°.3 (Verify RCS flow): "Required to be met in MODE 1 with all RCPs running.

SR 3.4.3.1 (Verify RCS P&T): "Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydro testing."

SR 3.4.11.1 (Cycle Block Valves): "Not required to be performed with block valve closed in accordance with the Required Actions of this LC0.

11 SR 3.4.12.3 (Verify SIT Isolated): "Required to be performed when complying with LCO 3.4.12b."

SR 3.4.16.2 (Verify 1-131): "Only required to be performed in MODE I. II Page 7 06/01/94

COMMENTS O~E RESTRUCTURED TECHNICAL SPECI~ATIONS

i.

SR 3.5.4.1 (Verify RWT Temp): "Only required to be performed when ambient air temperature is< 40°F or> l00°F.

I suggest addition of a leading "Only" to 3.4.1.3 & 3.4.12.3.

C.

Special SR Frequencies:

B.N. Young Special SR frequencies, which are not totally unique, are listed below.

I have made some suggestions with regard to consistency. Those notes which do not have any suggested changes are listed for comparison.

In addition to the suggested changes, I suggest that the use of {or lack of) "Once" be more consistent.

Usage appears somewhat random in the current version.

a.

SR 3.1.3.1 (Verify Core reactivity): "Prior to entering MODE 1 after fuel loading"

{Suggest: *Prior to entering MODE 1 after each fuel loading" as in 3.1.4.1.)

b.

SR 3.1.4~1 (verify MTC): "Prior to entering MODE 1 after each fuel loading"

c.

SR 3.1.4.2 (Verify MTC): "Each fuel cycle within.... " (two places)

d.

SR 3.1.5.7 (Verify CEA drop times): "Prior to reactor criticality after each removal of the reactor head" (Suggest: ~Prior to criticality after each removal of the reactor vessel head".

Compare with 3.4.2.1.)

e.

SR 3.1.8.2 (Verify CEA trip capability):. "Within [7 days]' prior to II

f.

SR 3 ~ 2. 2.1 (Verify F\\v): "Once prior to operation above 70% RTP after each fuel loading"

g.

h.

i.

j.

k.

(Suggest: "Once prior to operation > 70% RTP after each fuel l-0ading".

Compare with 3.2.3.1.)

SR 3.2.3.1 (Verify Fr,): "Prior to operation > 70% RTP after each fuel loading" SR 3.3~1.6 (Channel Functional Test - Rate of change & Loss of l-0ad): "Once within 7 days prior to each reactor startup" SR 3.3.1.7 (Channel Functional Test - Bypass removals): "Once within 92 days.prior to each reactor startup" SR 3.3.3.2 (Channel Functional Test - Manual Trip): "Once within 7 days prior to each reactor startup" SR 3.3.4.3 { (Channel Functional Test - Bypass removal): "Once wtthin 92 days prior to each reactor startup Page 8 06/01/94

COMMENTS ON~ RESTRUCTURED TECHNICAL SPECI~TIONS

1.

SR 3.4.2.1 (Verify Tavg): "Within 15 minutes prior to achieving criticality" (Suggest: "Within 15 minutes prior to criticality". Compare with 3.1.5.7.)

m.

SR 3.4.14.1 (Verify PIV leakage): "Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months"

{Suggest: "Prior to entering MODE 2 whenever the unit has been in MODE 5 or 6 for > 7 days, if not performed within 9 months".

Compare with 3.6.3.4 and 3.7.5.5.)

n.

SR 3.4.17.2 {Channel Functional Test* - Nls): "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to initiating startup or PHYSICS TESTS" (Suggest: "Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .prior to initiating startup or PHYSICS TESTS".)

o.

SR 3.5.1.4 (Verify SIT boron): "Once within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after... "

p.

SR 3.6.3.4 (Verify Cont lso Valves inside Cont)

(and 3.6.3 Action E.2): "Prior to entering MODE 4 from MODE 5 if not performed within*

the previous 92 days... "

{Suggest: "Prior to entering MODE 4 from MODE 5 if not performed within *92 days... " Compare with 3.4.14.1.)

q.

SR 3.6.3.6 (Test resilient Seal valves): "Within 92 days after opening the valve"

r.

SR 3.7.5.5 (Verify AFW flow path alignment): "Prior to entering MODE 2 whenever the unit has been in MODE 5 or 6 for > 30 days"

s.

SR 3.7.18.1 (Verify spent fuel burnup): "Prior to storing the fuel assembly in [Region 2]"

t.

SR 3.8.1.2 (Verify DG start): "As specified in Table 3.8.1-1" (Suggest: "In accordance with Table 3.8.1-1" as is done in all other instances of similar 'in accordante with' notes.)

u.

SR 3.8.6.2 (Verify cell parameters): "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after.

" {two pl aces)

D.

Placement of special limitations in applicability instead of using notes in SR:

B.N. Young

a.

LCO 3.4.2 {Minimum Tave) has a very complex applicability to limit the need to compl~te the SR during inappropriate conditions, where other LCOs

{3.2.1 and 3.4.3 in particular, in addition to those listed above) put such notes in the SR.

Page 9 06/01/94

COMMENTS O~E RESTRUCTURED TECHNICAL SPECl~ATIONS I suggest that the applicability of LCO 3.4.2 be 11 MODE 1, Mode 2 with K.11

~ 1.0." and that a note be added to SR 3.4.2.1 stating "Not required to be performed when T~* in all loops is > [535).F."

E.

Unexplained differences between parallel LCOs in different sections:

a.

LCO 3.4.10 (Primary Safties) vs 3.7.1 (Secondary Safties):

LCO 3.4.10 specifies a band of pressures for. the pressurizer safety valve setpoints; LCO 3.7.1 specifies the setpoint of each SG safety valve individually.

Both LCOs should be alike.

F.

Method of listing SRs from a related LCO which are applicable:

a.

SR 3.5.3.1 (ECCS - Shutdown): "The following SRs are applicable:"

(list provided.

b.

SRs 3.8.2.1 (AC sources-Shutdown) and 3.8.5.l (DC sources-Shutdown) list both some SRs which are not required to be performed and some

~hich are applicable; there is overlap between the lists. I find the method used in section 3.8 difficult and unclear.

I suggest that in each case the required SRs be listed.

G.

Test Exceptions:

LCO 3.1.8 and 3.1.9 refer to "Special Test Exceptions" and. use the abbreviation "STE"; LCO 3.4.17 refers to "Test Exceptions" without using any abbreviation.

LCO 3.0.7 discusses "Special Test Exception (STE) LCOs".

LCO 3.4.17 should be corrected.

H.

LCO 3.0.4 vs. SR 3.0.4:

B.N. Young These two LCOs have similar, but not identical wording, for portions which have identical. intent. The affected paragraph of each item is listed below with the subject sections highlighted:

~~~~1~:i~ij~g9641 ~~§ni::~*~ i:t:~~~~~~~ ~il~~~~~i~~:~~~j!~~;~~:::pg made?e'xce*tWheti the associated ACTIONS to be entered

.*.*.*.*.*.*.*.*.*.*.*.*.*.*.*.*.*.*:*:*.*:*.*.*.*.*.*.P*.*.*.*.*.*.*.*.*.*.*.*.*.. *.*.*.. *.

permff conffoued operation in the MODE or other LCO 3.0.4 i1Jiiliiia1amr SR 3.0.4 llllllllli';*d The highlighted portions should be identical.

Page 10 06/01/94

e COMMENTS ON CE RESTRUCTURED TECHNICAL SPECrrf CATIONS I.

LCO 3.0.l vs. SR 3.0.1:

Similarly to the 3.0.4s, the 3.0.ls have similar, but not identical wording:

LCD 3.0.1 --*-ll SR 3.0.1 ----~.

s"lfr";iellla'ri"C"e**~** ***whefhe**r:******iii'"ch"'***f a i 1 ure i s e xpe r 1 enced du r i ng the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have.to be performed on inoperable equipment or variables outside specified limits.

IV.

Structure CLCO, Applicability, Conditions SRs etc}:

A.

SR 3.1.5.2 (CEA *Alignment LCO) requires verification of CEA position indicator channel accuracy, but LCO 3.1.5 does not require any specific number of position indication channels to be operable & no Action is provided if position indication is inoperable or inaccurate.

B.

SRs 3.2.2.2 and 3.2.2.3 * (Peaking factor LCOs) verify parameters *which have no limit imposed by the LCO; there are no Actions provided by this LCO for FQ or Tq.

It appears that the determination of these parameters is simply part of the determination of F\\..,.

These SRs should be combined as "Verify the values of Tq, F*v' and Frq.

11

, or simply state in the basis that the determination of these other parameters is part of the determination of Frq.

C.

SRs 3.2.3.2 and 3.2.3.3 (Peaking Factor LCOs) verify parameters which have no limit imposed by the LCO; there are no Actions provided by this LCO for Fr or Tq.

It appears that the determination of these parameters is simply part of the determination of Fr,.

These SRs should be combined as "Verify the values of Tq, F~, and F~.

11

, or simply state in the basis that the determination of these other parameters. is part of the determination of Fr,.

D.

LCO 3.4.4 (RCS Loops Modes 1 & 2) has no SR to verify the operability required by the LCO.

The basis does not discuss those items necessary to make the RCS loops operable.

The SR which is provided is unnecessary, since the RPS will assure that mode 3 is entered quickly if an RCS loop is/\\,in operation.

The entire LCO seems to provide no-benefit.

tt_..

£.

LCO 3.4.11 (PORVs Modes 1, 2, & 3): This LCO states "Each PORV... "; most LCOs use the required number, rather than saying "each" or "all"..

F.

LCO 3.7.5 (AFW):

This LCO presents different requirements for different applicabilities by means of a note. That is different from the method used in other sections which use different LCOs when requirements change with plant B.N. Young Page 11 06/01/94

COMMENTS O~E RESTRUCTURED TECHNICAL SPECl~ATIONS conditions (see LCOs 3.1.l & 3.1.2, 3.3.1 & 3.3.2, 3.4.4 through 3.4.8, and all of section 3.8).

In order to be consistent, LCO 3.7.5 should be broken into a MODE l, 2, & 3 LCO and a MODE 4 LCO.

V.

Limits not specified in units available to the operators:

A.

SR 3.5.1.3 (SIT Level) has a special frequency which is based on a level change of IS of tank volume, as was required in the former STS.

Percent tank volume is not the parameter measured on the installed instrument.

Neither the basis nor the LCO provide the total tank volume to allow determining how much of an indicated level change triggers the requirement to perform the SR.

Assuming that the middle of the allowable level band is equivalent to half of the tank volume (which would be appropriate at Palisades) and using the numbers provided in the LCO and basis, we find that a "solution volume increase of ~ 1% of tank volume* is equivalent to a change of about 37 ft 3 (280 gallons) or 14.5%

indicated level. This is certainly misleading, having both percent indicated level and percent tank volume used in the same LCO.

8.

LCO 3.7.16 (Fuel Pool Level): This LCO refers to the fuel pool level in terms of feet above the fuel. That may not be the units available to, or used by, the operators.

At Palisades we typically measure levels like this by elevation*.

I suggest that the reference to 23 feet above the fuel be placed in brackets to allow utilities to insert their own units.

The conversion should be discussed in the bases.

C.

LCO 3.9.4 (SOC-High water level): see note about use of 23 feet for LCO 3.7.16.

0.

LCO 3.9.S (SOC-Low water level): see note about use of'23 feet for LCO 3.7.16.*

E.

LCO 3.9.6 (Refueling water level): see note about use of 23 feet for LCO 3.7.16.

VI.

Editorial and typographical A.

Lack of parenthetical notes explaining a SR or LCO quote such as "Perform SR 1.2.3.4", which were to be followed by a parenthetical (Quick description). A parenthetical repeat of the Condition statement was also to be included when a Condition was carried over onto another page.

8.

SR 3.6.2.2 (Verify airlock interlock after containment entry) wording should be altered to assure that the requirement only applies to the airlock used for the subject entry.

I suggest adding "affected" between "the" and "airlock".

VI I. Inconsistent Brackets fl :

A.

. LCO 3.1.5 (CEA Alignment) brackets the requirem~nt for a CEA motion inhibit and CEA deviation circuits, but the associated Actions (C & D) and SRs (3.1.5.3 &

3.1.S.4) are not bracketed.

B.

lCO 3.3.3 (RPS Logic & Trip Initiation): The requirement for reactor trip breakers "[four] charinels of reactor trip circuit breakers (RTCBs)," is not bracketed, nor are the associated RTCB references in the applicability, Conditions, or Actions.

The SR associated with RTCBs (SR 3.3.3.3) ~s bracketed.

The bracketing should be consistent. All CE units are not equipped B.N. Young Page 12 06/01/94

COMMENTS f cE RESTRUCTURED TECHNICAL SPEC,CATIONS with RTCBs, but Palisades may be the only exception.

Probably, there should be no brackets on the SR.

C.

LCO 3.3.4: Condition A (one CSAS channel inop), dealing with CSAS, is bracketed, but the CSAS exception in Condition B " (except CSAS inoperable)" is not bracketed.

Both should be bracketed.

VIII. Observations A.

The addition of "Neutron detectors may be excluded from CHANNEL CALIBRATIONS.

11 to the channel calibration definition would eliminate the need for repeating that note in each NI channel calibration SR.

It would be consistent with the addressing of thermocouples within the channel calibration.. definition. This would affect at least CEOG SRs 3.3.1.5, 3.3.2.4, 3.3.11.2, 3.3.13.3, and 3.9.2.2 B.

Notes which simply avoid Condition entry, when appropriate Action would and should be completed within the stated completion time anyway.

1.

LCO 3.1.6 (Shutdown Rod alignment): "This LCO is not applicable while performing SR 3.1.5.5".

2.

LCO 3.1.7 (Regulating Rod Alignment): "This LCO is.not applicable while performing SR 3.1.5.5 [or during reactor cutback operation].

3.

LCO 3.4.l (RCS Press, Temp, Fl~w) "Pressurizer pressure limit does not apply during:..

11 (power ramps and steps.)

C.

Unnecessary complexity:

1.

LCO 3.2.1 (LHR}, Condition A should simply read "LHR not within limits."

The balance of the information provided should reside in the basis, or possibly in the COLR.

Information on how to determine whether a parameter is within the limits does not need to be stated in the Condition.

2.

LCO 3.7.5 (AFW}: The Required Actions and completion times for Conditions D (3 trains inop in Mode 1, 2, or 3) and E (Req train inop in.Mode 4) are identical. It would be a bit cleaner and shorter to combine these two Conditions using an OR connector, as is done in many oth~r cases.

D.

Un-*necessary note Note (c) on CEOG table 3.3.1-1, page 1, (Analog) is unnecessary in.that it allows a trip to be bypassed at conditions which would place the plant out of the applicability for that trip.

E.

Redundancy B.N. Young SR 3.0.4 is redtu:ndant to the combined requirements of LCO 3.0.4 and SR 3.0.1.

SR 3.0.4 could be deleted without effect:

Simply stated, SR 3.0.4 prohibits changing Modes unless required SRs are current.{i.e. failed or not performed within the required period).

Similarly, LCO 3.0.4 prohibits changing Modes unless required equipment is Operable.

SR 3.0.1 states that if the required surveillance is current, the equipment is inoperable. Therefore, if a surveillance is not current, Page 13

' 06/01/94

COMMENTS O~E RESTRUCTURED TECHNICAL SPECI~ATIONS the associated equipment is inoperable and LCO 3.0.4 provides the same limitation as SR 3.0.4.

Indeed, a very literal reading could conclude that if a surveillance is not current, the equipment is inoperable (per SR 3.0.1) and therefore no surveillance is required (again, per SR 3.0.1) whereby SR 3.0.4 is totally without effect.

LCO 3.0.4, with this reading, would provide the desired restriction on Mode changes.

I believe that SR 3.0.4. should be deleted, thereby increasing both clarity (Why are there two limits?) and brevity.

I list the subject sections below, for reference.

The second paragraph of LCO 3.0.4 is not pertinent to this discussion.

LCO 3.0.4 When -an. LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other*

specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

SR 3~0.1 SRs shall be met during the MODES or.other specified conditions in the Applicability for individual lCOs, unless otherwise stated in the SR.

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

meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent passage through or to MODES or other specified conditions in compliance with Required Actions.

F.

Severe Required Action:

B.N. Voung The Required Action of CEOG STE LCD 3.4.17 seems unusually severe.

If power were to drift up to 6%, am immediate scram is required, yet the over power scram setpoints are specified at 20%.

It would seem that either a less severe Action shoul~ be provided for allowable excursions (if any excursion is acceptable) above the LCD limit, and the RPS setpoints be specified at the point where a scram is required.

Page 14 06/01/94

ENCLOSURE 4 Definitions 1.1 1.0 USE AND APPLICATION

. 1.1 Definitions*

~------------------------~NOTE------------------~------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

ACTIONS ASSEMBLY RADIAL PEAKING FACTOR (Fr A}

AXIAL OFFSET (AO)

AXIAL SHAPE-INDEX° (ASI)

AVERAGE

-DISINTEGBATION ENERGY (E)

PALISADES Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within* specified Completion Times.

ASSEMBLY RADIAL PEAKING FACTOR shall be the maximum ratio of the power generated in any fuel assembly, to the average fuel assembly power.

(Each of these power terms shall be integrated over core height and shall include tilt.)

AXIAL OFFSET shall be the ratio of the power generated in the lower. half of the core minus the power generated in* the upper half of the core,:to the sum of those powers

(~etermined using the Incore Detectors.)

AXfAL SHAPE INDEX shall be the ratio of the power generated in the lower half of the core minu~ the power generated in the upper half of the core, to the sum of those powers (determined using the Excore Detectors.)

AVERAGE DISINTEGRAJION ENERGY shall be the average (weighted in proportion to the concentration of each radionuclide in the primary coolant at the time of sampling} of the sum of the average beta and gamma energies per disintegration (in MeV} for isotopes, other than iodines, with half lives greater th~n 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.

1.1-1 Amendment: DRAFT, 05/25/94

1.1 Definitions CHANNEL CALIBRATION CHANNEL CHECK CHANNEL FUNCTIONAL TEST PALISADES Definitions 1.1 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors.

The CHANNEL CALIBRATION shall encompass the entire channel, including the sensor, alarm, interlock, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace cross calibration of the sensing elements and normal calibration of the remaining adjustable devices in the channel.

Neutron detectors may be excltided from a CHANNEL CALIBRATION.

The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel**

steps so that the entire channel is calibr~ted.

A CHANNEL CHECK shall be the qualitative assessment, by

. observation, of channel behavior during operation. This.

~etermination shall include, where possible, co~patison of the channel 'indication and status to other indications and status derived from independent instrument channels measuring the same parameter.

A CHANNEL FUNCTIONAL JEST shall be:.

a. Analog channels and _Bistable channels (e.g., pressure switches and switch contacts}-the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions;

b. Digital channels-the use of diagnostic programs to test digital hardware and the injection of simulated process data into the channel to verify OPERAB-ILITY, including

.required alarm, interlock, ~isplay, and trip functions.

The CHANNEL FUNCTIONAL TEST may be performed by means of any series pf sequential, overlapping, or total channel steps so that the entire channel is tested.

1.1-2

. Amendment: DRAFT, 05/25/94.

1.1 Definitions CORE ALTERATION CORE OPERATING LIMITS REPORT (COLR)

DOSE EQUIVALENT I-131 LEAKAGE PALISADES Definitions 1.1 CORE ALTERATION shall be the movement or manipulation of any fuel, sources, reactivity control components, or other components affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a saf~ position.

The COLR is the document that provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification $.'.;~~JW§.

Plant operation within these limits is addressea*rn individual Specifications.

DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as. the quantity and isotopic mixture of* I-131, I-132, I-133, I-134, and I-135 actually present.* The thyroid d6se conversion factors used for this calculation shall be those listed in Table III of TID-14844,. AEC, 1962, "Calc~lation of Distance Factors for Power and Test Reactor Sites".

LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE, such ai that from pump seals or valve packing (e~cept primary coolant pump (PCP) seal leakoff), that is captured and conducted to collection systems, a.

sump, or* a collecting tank; *

l. LEAKAGE into the containment atmosphere from*sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE; or

3. Primary Coolant System (PCS) LEAKAGE through a steam generator (SG) to the Secondary System.

b. Unidentified LEAKAGE All LEAKAGE that is not identified LEAKAGE.

c. Pre~sure Boundary LEAKAGE LEAKAGE (except SG tube LEAKAGE) through a nonisolable fault in an PCS component body, pipe wall, or vessel wa 11.

1.1-3 Amendment: DRAFT, 05/25/94

1.1 Definitions MODE OPERABLE -

OPERABILITY PHYS I CS TESTS QUADRAN,T POWER TILT (TQ)

RATED THERMAL POWER (RTP)

PALISADES

~

Definitions 1.1 A MODE shall correspond to any one inclusive combination of core reactivity condition, power level, average primary coolant temperature, and reactor vessel head closure stud tensioning.specified in Table 1.1-1, with fuel in the reactor vessel.

A system, subsystem, train, component, or device shall be OPERABLE, or have OPERABILITY, when it is capable of performing its specified safety functions and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, :and other auxiliary equipment that are required for the sys1t1em, subsystem, train, component, *or devic:;e to perform its specified safety functions are also capable of performing their related support functions.

PHYSICS TESTS shall be those tests performed to measure the fundamental. nuclear characteristics-of the reactor core and related instrumentation. These tests are:

a. Authorized under the provisions of 10 CFR 50.59; or

b. Otherwise approved by the Nuclear Regulatory Commission.

QUAD~ANT POWER TILT shall be the maximum positive.ratio of the power generated in any quadrant minus the average quadrant power, to.the average quadrant power.

RTP shall be a total reactor core heat transfer. rate to the primary cooilant of 2530 MWt.

1.1-4 Amendment: DRAFT, 05/25/94

1.1 Definitions SHUTDOW.N MARGIN (SOM)

STAGGER£D TEST BASIS THERMAL POWER TOTAL RADIAL PEAKING FACTOR

( F rT}

PALISADES Definitions 1.1 SOM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a. All full length rods (shutdown and regulating) are fully inserted except for the "single rod of highest reactivity worth, which is assumed to be fully withdrawn.

However, with all rods verified fully inserted by two independent means, it is not necessary to account for a stuck rod in the SOM calculation.

b. In MODES 1 and 2, the fuel and moderator temperatures are changed to 532"F.

c. There is no change in part length.rod position.

With any rods not capable of being fully inserted, the reactivity worth of these rods must be accounted for in the determination of SOM.

A STAGGERED TEST BASIS shall consist of the testing of one

. of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all sy5tems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER shall be the total reactor* core heat transter rate to the primary coolant.

The TOTAL RADIAL PEAKING FACTOR shall be the maximum product of the ratio of individual assembly power to core average assembly power, times the highest local peaking factor integrated over the total core height, including tilt.

Local peaking factor is defined as the maximum rati~ of an individual fuel rod power to the assembly average rod power.

1.1-5 Amendment: DRAFT, 05/25/94.

MODE TITLE

. 1 Power Operation*

2 Startup 3

Hot Standby 4

Hot Shutdown(a) s Cold Shutdown(a) 6 Refueling(b)

Table 1.1-1 MODES REACTIVITY CONDITION

( kofl)

~ 0.99

< 0.99

< 0.99 NA

% RATED THERMAL POWER

> 5 s 5 NA NA NA NA Definitions 1.1 AVERAGE PRIMARY COOLANT TEMPERATURE

(*F)

NA NA

~ 300 300 > Tave > 200 s 200 NA (a)

All reactor vessel head closure studs fully tensioned.

(b) *One or more r~actor vessel head closure studs less than fully tensioned.

PALISADES 1.1-6 Amendment: DRAFT, 05/25/94

Logic~Y Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE BACKGROUND EXAMPLES CEOG STS The purpose of this section is to explain the aeaning of logical connectors.

/Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times.

- Surveillances, and Frequencies.

The only logical connectors that appear in TS are AND and OR.

The physical aiTrrangement of these connectors constitutes logical conventions with specific meanings.

Several levels of logic may be used to state Required Actions.

These levels are identified by the placement (or*

. nesting) of the l ogi cal connectors and by the number assigned to each Required Action.

The first level of logic is identified by the first digit of the number assigned to a Required Action and the p 1 acement of the 1 ogi ca*l connector in the first level of nesting (i.e., left justified with the

number of the Required Action).. The successive.levels of logic are identified by additional digi.ts of the* Required Action number and by successive indentions of trre l ogi ca.1 connectors.

\\rJhen logical connectors are used to state a Cond'ition, only the first level of logic is used, and the logical connector is left justified with the Condition statement.

... ~ -... ** ~

When logical connectors are used to state a.Completion Time; Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of theACompletio~ Time, Surveillance. or Frequency.

The following examples illustrate the. use of fogical connectors.

(continued) 1.2-1 Rev.

0, 09/28/92

,j Logi ca 1 Connectors

1.2 1.2 Logical Connectors EXAMPLES (continued)

CEOG STS EXAMPLE 1. 2-1 ACTIONS CONDITION REQUIRED ACTION A. LCO not met.

A.l Verify.

A.2 Restore...

COMPLETION TIME In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.l and A.2 must.be completed.

(continued) 1.2-2 Rev.

0, 09/28/92

1. 2 Logical EXAMPLES (continued)

CEOG STS Logical Connectors

1. 2 Connectors EXAMPLE 1. 2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

LCO not met.

A.1 Trip....

OR A.2.1 Verify...

AND A.2.2.1 Reduce OR A.2.2.2 Perform OR A.3 Align This example. represents a more complicated use of logical connectors.

Required Actions A.l. A.2. and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement.. Any one of these three Actions may be chosen.

If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND.

Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2.

The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

1.2-3 Rev.

0, 09/28/92

Completion Times

1. 3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION C£DG STS fhe purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

. ~~ ~-.. - -

LCOs specify minimum requirements for ensuring safe operation of the unit.

The ACTIONS associated with an LCO state Conditions that typically describe the ways in*which the requirements of the LCO can fail to be met.

Specified with each stated Condition are Required-Action(s} and Completion Time(s}.

The Completion Time is the amount of time allowed for completing a Required Action.

It*is referenced to the time of discovery of a situation (e~g~ *. inoperable equipment or variable not within limits} that requires entering an *

ACTIONS Condition unless otherwise specified, providing_ the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Required Actions'must be completed prior to the exp.i.ration of the specified.

. Completion Time.

An ACTIONS Condition_remains in effect ~nd the Required Actions apply-until the Condition no longer exists or the unit is not within the.LCO Applicability.

~* -~*

.. -...7 c_. -

~ ~

~.-

! }-:.....

T'. !. ' ~ C' If situations*a~e di~covered that requir~ entry into more than one Condition at a time within a.single LCO (multiple Conditions}. the Required Actions for each Conditiori must b~

perfonned within the associated Completion Time.

When in multiple Conditions, separate Completion.Times are tracked for each Condition starting from th~ time of discovery of _

the situation that required entry into the Condition. f*1.**r

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the.

. Condition, discovered to be inoperable or not within limits.

will not result in separate entry into the Condition, unless specifically stated.

The Required Actions of the Condition.

continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

r. <. ~* - f--

/. } /

6!.;t...... Pr rf:.&...

1.3<~~ C., o*~ r.

,f:_!.~..

~-f~.,.,,,,!

f".1,'(

~

(continued}

1. 3-1 Rev.

0, 09/28/92

Completion Times

1. 3 1.3 Completion Times DESCRIPTION (continued)

CEOG STS ffowever, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a.

Must exist concurrent with the first inoperability;

and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The *total Completion Time allowed for completing a Required Action to address the.subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 ho.urs; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Comp*letion Time extensions: do not apply to those

Specifications that have exceptions that allow completely

s~parate re-entry into the !ondition (for* each train, subsystem, component, or variable expressed in the Condition} and separ~te tracking of Completion Times based on this re-entry.

These exceptions are stated in individual

.. s.peci f i cations.

The ab_ove Completion Time extension does not apply to a Completion Time with a modified "time zero.

11 This modified "time. zero" may be expressed as a repetitive time (i.e.,

. "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as*a time modified by the phrase 11 from discovery ***

11 Example 1.3-3 illustrates one use of this type of Completion Time.

The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

(continued) 1.3-2 Rev.

0, 09/28/92

Completion Times

1. 3

.1.3 _Completion Ti"1e~ (c_ont_inued)

EXAMPLES CEOG STS The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.*

EXAMPLE "1.3-1 ACTIONS CONDITION B. Required Action and associated Comp 1 et ion Time riot

[.

met.

REQUIRED ACTION COMPLETION TIME B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND B.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions.* Each Required Action has its own separate Completion Time.

Each Completion Time is ref~renced to the.time that Conditicin B is entered.

The Re4uired Actions of Condition B are to tie *in MODE 3

within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

A total. of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed for reaching MODE 3 and a total of-

. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 42 hour4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months s} is allowed for reaching MODE 5 from the time that Condition B was entered.

If MODE 3 is reached within 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months s~ the time allowed for*reaching MODE 5 is the next 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

lf Condition Bis entered while in MODE 3,"the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued) 1.3-3 Rev.

0, 09/28/92

Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

CEOG STS EXAMPLE 1.3-2 ACTIONS CONDITION A. One pump inoperable.

B. Required Action and associated Completion Time not met.

A.1 B.l AND B.2 REQUIRED ACTION COMPLETION TIME Restore pump to 7 days OPERABLE status-.

Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a pump is declared inoperable~ Condition A is entered.

If.. the pump 1s not restored to OPERABLE status within 7 days,.condition B is entered and the Completion Time clocks for Required Actions B.l and 8.2 start.

If the inoperable pump is restored to OPERABLE status.after Condition B is entered, the Require*d Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.

LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump.

The Completi6n Time tlock for Condition A does not stop after LCO 3.0.3 is entered, but coniinues to be tracked from the time Condition A was initially entered.

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.

(continued) 1.3-4 Rev.

0, 09/28/92

~.... '

Completion Times 1.3 1.3 Completion Times EXAMPLES CEOG STS EXAMPLE 1.3-2 {continued)

While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Ti~e for Condition A has expired, LCO 3.0.3 may be exited and operation continued in ~ccordance with Condition*B.

The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.

On restoring one of the pumps to OP.ERABLE status, the Condition A Completion Time is not ~eset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump.

A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for

?' 7 days.

(continued)

1. 3-5 Rev.

0, 09/28/92

v 1.3 Completion Times EXAMPLES (continued)

."\\

CEOG STS EXAMPLE 1.3-3 ACTIONS CONDITION A. One Function x train inoperabl~.

.8 ~ One Function* Y train inoperable.

c. One Function x train inoperable.

AND One function y train inoperable.

REQUIRED ACTION A. l Restore Function X train to OPERABLE status.

8.1 Restore Function Y train to OPERABLE status.

C.1 Restore Function X train to OPERABLE status.

OR C.2 Restore Function Y train to OPERABLE status.

1.3-6 Completion Times

1. 3 COMPLETION TIME 7 days AND 10 days from discovery of failure to meet the LCO 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCO.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Rev.

0, 09/28/92

Completion Times

1. 3

1. 3 Comp l etfo-n Ti mes EXAMP.LES CEOG STS EXAMPLE 1.3-3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable.

The Completion Times for Conditio~ A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condi.tion was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time.the

situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited.

If the Completion 'lime for Required Action A.1 has not expired, operation may continue in accordance with Condition A.

The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e.*

initial entry into.Condition A).

The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met.

In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner'that operation could continue indefinitely without ever restoring systems to meet the LCO.

The separate Completion Time modified by the phrase 11 f.rom

~discovery of failure to meet the LC0 11 is designed to prevent indefinite continued operation while not meeting the LCO.

This Completion Time a)lows for an exception to the normal "time zero" for beginning the Completion Time 11clock.

11 In this instanc_e, the Completion Time utime zero" is specified as connencing at the.time the LCO was initially not met, instead of at the time the associated Condition was entered.

(continued)-

1.3-7 Rev.

0, 09/28/92

Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

CEOG STS

r EXAMPLE 1. 3-4 ACTIONS CONDITION A. One or more valves inoperable.

'.8. Required Action and associated

,completion Time not met.

f A.1 8.1 AND 8.2 REQUIRED ACTION COMPLETION TIME

. Restore valve(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to OPERABLE status.

Be in.MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A single Completion Time is used for ~ny number of valves

. inoperable at the same time.

The Completion Time associated

~ith Condition A is bas~d on the i~itial ~ntry into tondition A and i~.~ot tr~cked on a per valve basis.

. Declaring subsequent valves inoperable, while Condition A is

.. still in effect, does not trigger the tracking of.separate Completion Times.

Once one of the valves has been restored to* OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable.

The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve.

The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provided this does not result in any subsequent valve being inoperable for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

If the Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (including any extensions) expfres while one or more valves are still inoperable, Condition B is entered.

(continued) 1.3-8 Rev.

0, 09/28/92

' ~

Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)

CEOG STS EXAMPLE 1. 3-5 ACTIONS

NOTE----------------------------

Separate. Condition entry is a1lowed for each inoperable valve.

CONDITION REQUIRED ACTION COMPLETION TIME A'. One or more A.1 Restore valve to 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s*

valves OPERABLE status.

inoperable.

B. Required B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated ANO Completion Time not B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months met.

The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked.

If this method of modifying how the Completion Time is tracked was applicable only to Condition A, the Note may appear in the Condition column.

The Note allows Condition A to be entered separately for

each inoperable valve, and Completion Times tracked on a per valve basis.

When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared irioperable, Condition A is entered for each valve*and separate Completion Times start and are tra~ked for each-valve.

(continued) :

1.3-9 Rev.

0, 09/28/92

Completion Times.,**

1.3 1.3 Completion Times EXAMPLES

.CEOG STS EXAMPLE 1.3-5 (continued)

If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve.

If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Ca11pletion Times start and are tracked for each valve.

If a va 1 ve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve.

Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.

EXAMPLE 1.3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A. l Perform Once per

-~: ~ rt t ')... \\."'.

inoperable.

SR 3. x. x. x..

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months -

.~

I~

~

OR

~

~.* 't :.

A.2 Reduce THERMAL 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s-POWER to

. -~ 50% RTP.

B. Required B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and

./

' associated

~ < ~1,. /

~.(_

Completion J -

l' Time not

./!re..

T;}itiE:"-1

'met.

P.c.co..-.. PL' Sllrt.!)

(continued) 1.3-10 Rev.

0, 09/28/92

Completion Times 1.3 1.3 Completion Times EXAMPLES CEOG STS EXAMPLE 1.3-6 {continued)

Entry into Condition A offers a chofce between Required Action A.l or A.2.. Required Action A.l has a *once p~r" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, *to each perfonnance after the initial perfonnance.

If Required Action A.l is followed and the Required Action is not met within the Completion Time {including the 25%

extension allowed by SR 3.0.2), Condition Bis entered.

If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not met, Condition B is entered.

If after entry into Condition 8, Required Action A.l or A.2 is met, Condition B is exited and operation may then continue in Condition A.

(contin~ed) 1.3-11 Rev.

0, 09/28/92

C.ompletion Times

1. 3 1.3 Completion Times EXAMPLES

{continued)

CEOG STS EXAMPLE 1.3-7 ACTIONS CONDITION A. One subsystem inoperable.

B. Required Action and

associated Completion Time not met.

A. l AND A.2 B.1 AND B.2 REQUIRED ACTION COMPLETION TIME Verify affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months subsystem isolated.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter Restore subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to OPERABLE status.

Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months '

Be in MODE 5.

' 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Required Action A.l has two Completion Times.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Compl~tion Time begins at the time the Condit{on is entered and each "Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter" interval begins upon performance of Required Action A.l.

If after Condition A is entered, Requi~ed Action A.l is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (including the 25% extension allowed by SR 3.0.2), Condition Bis entered.

{continued) 1.3-12 Rev.

0, 09/28/92

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-7 (continued)

The Completion Time clock for Condition A does not stop.

after Condition B is entered, but continues from the time Condition A was initially entered.

If Required Action A.l is met after Condition B is eniered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired. Since the second Completion Time of Required Action A.l has a modified Ntime zero* (i.e., after the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , not from time of Condition entry}, the allowance for a Completion Time extension does not apply.

IMMEDIATE When 11 Imnediately 11 is used as. a Completion Time, the COMPLETION TIME Required Action should be pursued without-delay and in a controlled manner.

CEOG STS 1.3-13 Rev.

0, 09/28/92

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE DESCRIPTION EXAMPLES CEQG STS The purpose of this section is to define the proper use and appljcation of Frequency requirements.

. ?ttr.f=-~~f:. -:...

Each Surveillance Requirement (SR) has ecified Frequency in which the Survefllance must b~

.in order to meet the associated LCO.

An understanding of the correct application of the specified Frequency is necessary for compliance with the S.R.

The "specified Frequency* is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability.

The "specified

.. Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Survei 11 ance column. that mod.ify perfonnance requirements.

Situati.ons where a Surveillance could be required (i.e. I its Frequenc~ could expir~). but where it is not possible or not

desired that' ft be performed until 'sbmeti~.e after the

associated LCO js within its Applicability, represent potential SR 3.0.4 conflicts.

To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is ~nly "required" when it can be and should be perfonned.

With an SR satis.fied, SR 3.0.4 imposes no*

restriction.

The following examples illustrate the various ways that Frequ~ncies are specified.

Iri these examples, the Applicability of the LCO tt£~t.,jhown) *fs MODES l, 2,

. and 3.

(continued) 1.4-1 Rev.

0, 09/28/92

l. 4 Frequency EXAMPLES (continued)

~ 't*

I

.-. f *:<.*

CEOG STS Frequency 1.4 EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the rechnical Specifications (TS).

The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Survefllance must be perfonned at least one time.

Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for ~perational flexibility.

The.measurement of this interval continues at

.. all times. even when the SR is no~ required to be met per SR 3.0.1 (such as when the ~quipment is inoperable, a variable is outside specified limits, or. the unit is outside the Applicability of the. LCO).

If the interval specified by SR 3.0.2 is exceeded while the unit i.s in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Survei 11 an*ce is not otherwise modified

-~(refer to Example 1.4-3). then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE.or other speciffed condition in the Applicability of the LCO for which performance of the SR

- is required. the Survei 11 ance must be *performed within the

Frequency requirements of SR 3. 0. 2 prior to entry into the MODE or other specified condition.

Failure to do so would result in a violation of SR 3.0.4.

(continued) 1.4-2 Rev. 0, 09/28/92

1. ~ Frequency*

EXAMPLES (continued)

CEOG STS EXAMPLE 1.4-2

.. SURVEILLANCE REQUIREMENTS SURVEILLANCE Frequency

1. 4 FREQUENCY

~-------..

__, ~

Once within ours after

!:. 25% RTP

..,~'-*-. **t...,'l c --

Verify flow is within limits.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter Example 1.4-2 has two Freq~encies. The first is. a one time perfonnance Frequency, and the second is of the type shown

.in Example 1.4-1.

The logical connector 11 AND 1

~ indicates that both *Frequency requirements must be met.

Each time*

reactor power is increased from a power level < 25% RTP to

!:. 25% RTP, the Surveillance must be perfonned within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The use of "once" indicates a* single perfonnance wi 11.

satisfy the specified Frequency (assuming no other Frequencies are connected by *AND*).

Thi.s type of Frequency does not qualify for the*25~ extension allowed by SR 3.0.2.

11 Thereafter 11 indkates future perfonnances must be established per SP 3.0.2, but only after a specified condition is first met (i.e., the "once" perfonnance in this example}.

If reactor power decreases *to_< 25% RTP, the

measurement of both intenals stops.

New intervals start*

upon reactor power reaching 25% RTP.

(continued) 1.4-3 Rev.

0, 09/28/92

~.... : :.'E

1.4 Frequency EXAMPLES (continued)

CEOG STS EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE

NOTE------------~-----

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after ~ 25% RTP.

Perform channel adjustment.

Frequency 1.4 FREQUENCY 7 days The interval continues, whether or not the unit operation is

< 25% RTP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after power reaches ~ 25% RTP to perform the Surveillance.

The Surveillance is still considered to be performed within the "specified Frequency.

11 Therefore, if the Survei 11 ance were not performed within the 7 day (plus 25% per SR 3.0.2) interval, but operation was< 25% RTP, it would not constitute. a failure of the SR or failure to meet "the LCO.

Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation doe~ not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with power ~ 25% RTP.

Once the unit reaches 25% RTP, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months would be allowed for completing the Surveillance.

If the Surveillance were not performed within this 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval, there would then be a failure to perform a Surveillance within the specified Frequency; MODE changes then would be restricted in accordance with SR 3.0.4 and the provisions of SR 3.0.3 would apply.

1.4-4 Rev.

0, 09/28/92 41

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 (continued)

LCD' 3.0.5 LCD 3.0.6 CEOG STS Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

Exceptions to this Specification are stated in the.

individual Specifications. These exceptions allow entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered allow unit operation in the MOOE or other specified condition in the Applicability only fdr a limited period of time.

Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative {ontrol solely to.perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other

-equipment.

This is an exception to LCO 3.0.2 'for the 5ystem returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

When a supported system LCO js not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required.to be entered.

Only the support syste~ LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system.

In.this event, additional evaluations and limitations may be required in

- accordance with Specification 5.8, "Safety Function Oetermi nation Program (SFDP)."

If a 1 oss of safety function is determined to exist by this program, the appropriate tonditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and.Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LC0*3.0.2.

3.0-2 (continued)

Rev.

0, 09/28/92

'* '1

LCO Applicability 3.0

t.

I.}

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 CEOG STS LCOs shall be met during the MODES or other specified conditions in the Ap~lic~lity, except as provided in LCO 3.0.2@~{LCO 3~_.. 7.

~1.. 1 ~,.,.ce""'

,,,..,,..r

.J~-.-

i..lt~">

/,./t:.

~ )((. ~ p i'l:.i~ ':::..

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

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

When an LCO is not met and the associated ACTIONS are not met or an associated ACTION is not provided, the unit shall be placed.in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated wi~hin

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicab)e. in:

a.

MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ; b... {MODE 4 wi thi nrkhours] ;. and'

c.

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

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are comp 1 eted 'that permit operation in accordance with the LCD or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

"~"!""

S"" ~*f't.C,.

LCO 3.0.3 is~.applicable in MODES 1, 2, 3,---ilrnit e":"*'*'t.~~* '>.:t c <'L'--..

~P?'.J.t *

~.= : -:-. ~t.. c,.

11\\'.'1.'

~-,*~-

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the ass'oci ated ACTIONS to be entered penni t continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

This (continued) 3.0-1 Rev.

0, 09/28/92

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued).

,/

_,,/".

,,/""

LCO 3.0*.7 CEOG STS Special test exception (SJ-f) 'icos [in each applicable LCD

- -.section] allow specifj~ Technical Specifications (TS)

L~.0.7 requir~rits to be changed to permit performance of speci-aJ testi and operations. Unless otherwise specifie~

other TS requirements remain unchanged.

Compltan-ce wit E LCOs is optional.

When an STE LCO is desi"t"'ed to be met b is not met, the ACTIONS of the STE LCD

.......sflall be met.

When an STE LCO is not desired to be met,

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

3.0-3 Rev.

0, 09/28/92

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 CEOG STS SRs shall be 11et during the MODES or other specified conditions in the Applicability for individual LCOs. unless otherwise stated in the SR.

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

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

Surveillances do not have to be perfonned on inoperable equiimielibt or variables outside specified limits.

The specified Frequency for each SR is met if the SurveHlance is perfonned within 1.25 times the interval specified in the Frequency. as measured from the previous perfonnance or as measured from the time a specified condition of the Frequency is met.

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

If a Completion Time requires periodic perfonnance on a uonce per... " basis, the above Frequency extension c.pplies to each perfonnance after the ini'tial perfonnance.

Exceptions to this Specification are stated in the individual Specifications.

lf it is discovered that a Surveillance was not perfonned within its specified Frequency, then compliance with the

.requirement to dee 1 a re the LCO not met may be de 1 ayed, from the time of discovery. up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency. whichever is less. This delay period is permitted to a 11 ow perfonnance of the Surveillance.

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

The Completion Times of the Required Actions begin inmediately upon expiration of the delay period.

(continued) 3.0-4 Rev.

0, 09/28/92

...... *.. \\*.

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'I.***~~..

.i.,..

4

.. -;°;:~~~~EE! ING

SUMMARY

FOR MING HELD ON 6/14 /94 DISTRIBUTION W/ENCLOSURES 1. 2, 3. & 4 Docket File NRC & LPDRs PD31 Reading W. Kropp, Riii -

M. Parker, SRI A. Hsi a DISTRIBUTION WITH ENCLOSURE 1 AND 2 W. Russell/F. Miraglia, 12/G/18 R. Zimmerman J. Roe J. Zwolinski L. B. Marsh C. Jamerson OGC E. Jordan MNBB-3701 C. Grimes R. Tjader N. Gilles ACRS (10)

B. McCabe, 17/G/21

. DATED:

July 20, 1994

ML18059B119

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ML18059B119

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