TSTF-18-03, Transmittal of TSTF-565, Revision 1, Revise the LCO 3.0.2 and LCO 3.0.3 Bases

Transmittal of TSTF-565, Revision 1, Revise the LCO 3.0.2 and LCO 3.0.3 Bases

ML18089A064
Person / Time
Site:	Technical Specifications Task Force
Issue date:	03/30/2018
From:	Gullott D, Miksa J, Sparkman W, Vaughan J, Linda Williams Technical Specifications Task Force
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-18-03
Download: ML18089A064 (29)

Text

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF March 30, 2018 TSTF-18-03 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-565, Revision 1, "Revise the LCO 3.0.2 and LCO 3.0.3 Bases" Enclosed for NRC review is TSTF-565, Revision 1, "Revise the LCO 3.0.2 and LCO 3.0.3 Bases." Revision 1 is based on discussions held between the TSTF and the NRC at the November 9, 2017 public meeting. TSTF-565, Revision 1, is a complete replacement for Revision 0, which was titled, "Clarify the Term Operational Convenience in the LCO 3.0.2 Bases."

The Technical Specifications Task Force should continue to be billed for the review of the traveler.

Should you have any questions, please do not hesitate to contact us.

James P. Miksa (PWROG/CE)

Lisa L. Williams (BWROG)

David M. Gullott (PWROG/W)

Jordan L. Vaughan (PWROG/B&W)

Wesley Sparkman (APOG)

Attachment cc:

Michelle Honcharik, Technical Specifications Branch Robert Tjader, Technical Specifications Branch Victor Cusumano, Technical Specifications Branch

TSTF-565, Rev. 1 PWROG-1, Rev. 0 NUREGs Affected:

Revise the LCO 3.0.2 and LCO 3.0.3 Bases Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Changes Marked on ISTS Rev 4.0 2194 See attached justification.

Revision History OG Revision 0 Revision Status: Active Original Issue Revision

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

10-Jan-17 Owners Group Comments (No Comments)

Date: 02-Feb-17 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

01-Feb-17 Date Distributed for Review 21-Feb-17 TSTF Comments:

(No Comments)

Date: 09-May-17 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

10-May-17 At the November 8, 2017 TSTF/NRC public meeting, the TSTF agreed to revise TSTF-565 to provide a more comprehensive change to the LCO 3.0.2 and LCO 3.0.3 Bases, reflecting the requirements in the Maintenance Rule.

08-Nov-17 Superceded by Revision NRC Comments:

Final Resolution:

Final Resolution Date:

TSTF Revision 1 Revision Status: Active 30-Mar-18 Copyright(C) 2018, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-565, Rev. 1 PWROG-1, Rev. 0 Affected Technical Specifications TSTF Revision 1 Revision Status: Active Revision 1 is a complete replacement of Revision 0. The traveler title, originally "Clarify the Term Operational Convenience in the LCO 3.0.2 Bases," was revised to reflect the revision.

Revision

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

18-Jan-18 Owners Group Comments (No Comments)

Date: 16-Feb-18 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

07-Mar-18 Date Distributed for Review 07-Mar-18 TSTF Comments:

(No Comments)

Date: 30-Mar-18 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

30-Mar-18 LCO 3.0.2 Bases Use and Application LCO 3.0.3 Bases Use and Application 30-Mar-18 Copyright(C) 2018, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-565, Rev. 1 Page 1 1

SUMMARY

DESCRIPTION The Bases of limiting conditions for operation (LCO) 3.0.2 and LCO 3.0.3 are revised to eliminate ambiguity and to reflect current regulatory requirements regarding planned removal of systems from service.

2 DETAILED DESCRIPTION

2.1 Background

Technical specifications contain LCOs and associated remedial actions to be performed when an LCO is not met as required by Title 10 of the Code of Federal Regulations (CFR), Part 50, Paragraph 50.36(c)(2)(i):

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 specifications until the condition can be met.

TS Section 3.0 Requirements Standard Technical Specifications (STS) Section 3.0, "Limiting Condition for Operation (LCO)

Applicability," provides general rules for applying the Technical Specifications (TS).

In Revision 4 of the STS, NUREG-1430 through -1434, and Revision 0 of NUREG-2194, LCO 3.0.1 states, in part:

LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 LCO 3.0.2 states, in part:

Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met...

LCO 3.0.3 states, in part:

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

Although the wording of these provisions has changed over time, the requirements have remained essentially the same for almost 40 years.

LCO 3.0.2 and LCO 3.0.3 do not address why an LCO is not met or limit whether such a condition is intentional or unintentional; planned or unplanned. These provisions simply state the remedial actions to be taken when an LCO is not met to remain in compliance with the TSs and 10 CFR 50.36.

TSTF-565, Rev. 1 Page 2 TS Bases 10 CFR 50.36 (a)(1) states:

Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications. (emphasis added)

Per this regulation, the TS Bases explain the reasons for the specifications, but the Bases are not regulatory requirements.

In the early versions of the STS, such as NUREG-0452, the Bases of the Section 3.0 requirements (equivalent to LCO 3.0.2 and LCO 3.0.3) simply restated the TS requirement. In the current STS, the LCO 3.0.2, and LCO 3.0.3 Bases are more extensive and discuss the basis of the timing of Actions, the types of Actions, intentional entry into actions, and the basis for the exceptions to following Actions.

The description provided in the LCO 3.0.2 Bases aligns with the requirements in TS LCO 3.0.2 except for the following paragraph:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. Reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety.

Intentional entry into ACTIONS should not be made for operational convenience.

Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

This paragraph discusses the licensee's purpose for entering Actions and applies restrictions on intentionally entering Actions. These statements do not correspond to any specific requirement in LCO 3.0.1 or LCO 3.0.2.

The LCO 3.0.3 Bases describe the requirements in TS LCO 3.0.3 except for the following statement:

[LCO 3.0.3] is not intended to be used as an operational convenience that 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.

TSTF-565, Rev. 1 Page 3 Generic Letter 87-09 The LCO 3.0.2 and LCO 3.0.3 Bases statements cited above originally appeared in Generic Letter (GL) 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," dated June 4, 1987 (Reference 1). GL 87-09 provided TS improvements to resolve immediate concerns that had been identified in investigations of TS problems by both the NRC and the industry. GL 87-09 addressed three issues: unnecessary restrictions on mode changes, unnecessary shutdowns caused when surveillance intervals are inadvertently exceeded, and two conflicts between Specifications 4.0.3 and 4.0.4.

GL 87-09 did not propose any changes to the equivalent of LCO 3.0.2, or 3.0.3. However, the GL provided proposed changes to the Bases for these requirements that were not discussed in GL 87-09 and went beyond the three issues by adding statements regarding intentional entry into TS actions. Enclosure 3 to GL 87-09 provided revised Bases for pressurized water reactors (PWRs) and Enclosure 5 provided revised Bases for BWRs. The recommended Specification 3.0.1 Bases stated:

It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of redundant system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The recommended PWR Bases for Specification 3.0.3 stated:

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.

These Bases statements are not surprising to licensees. The U.S. Nuclear Regulatory Commission (NRC) had long recognized that licensees may enter Actions voluntarily for many reasons. For example, in Reference 2, issued in 1979, the NRC stated:

"[I]t should be noted that throughout the STS [Standard Technical Specifications], and typically in the custom technical specifications, the licensee is not prohibited from voluntarily entering action statements. We believe it is necessary and desirable to structure the technical specification to permit the operator to exercise judgment within the latitude permitted by Technical Specifications. It should be further noted that during operation in a degraded mode under the provisions of an action statement, the facility may not be capable of responding to an initiating event plus a concurrent or subsequent single failure of an active component. Therefore, the action statements restrict operation in the specified degraded mode of operation to a limited period of time." (emphasis added)

TSTF-565, Rev. 1 Page 4 The NRC also recognized that there may be circumstances in which licensees intentionally enter LCO 3.0.3. In a 1987 memorandum from the NRC Region V Administrator to the NRC Director of the Office of Nuclear Reactor Regulation, (Reference 3), the Administrator stated:

[As a result of the review of a recent event], Region V has concluded that it may be beneficial for the NRC to reiterate to both the NRC staff and power reactor licensees, the intent of LCO 3.0.3 and our expectations concerning licensee management control of entry into LCO 3.0.3.... Region V recognizes that occasional entry into LCO 3.0.3 for surveillance or maintenance purposes may be appropriate, however, this activity should be well thought-out in advance and strictly controlled by management oversight and appropriate procedures.

Note that this memorandum was written in March 1987 and GL 87-09 was published in June 1987.

A search of the NRC docket in the time of the GL 87-09 development finds the term "operational convenience" used in its usual, English meaning, such as "The flush ports are provided as an operational convenience to flush the exhaust line out of any corrosion products," or "For operational convenience, 40% of rated power has been chosen as the setpoint below which these trips are bypassed." TS Actions have historically been entered for the convenience of performing required Surveillances online instead of shutting down the plant to perform the tests.

Based on the historical context, the GL 87-09 Bases were not discouraging entering Actions for operational convenience, but were discouraging routine, voluntary removal of redundant system(s) or component(s) from service when other alternatives were available.

As part of the industry/NRC Technical Specifications Improvement Project, the Boiling Water Reactor Owners' Group, Westinghouse Owners Group, Combustion Engineering Owners Group, and B&W Owners Group proposed improved STS in 1989 (References 4, 5, 6, and 7). The proposed LCO 3.0 Bases were very similar to the TS Bases enclosed in GL 87-09. The Owners Groups' documents were the basis of the current STS. During the development of LCO 3.0.2 Bases in the draft STS, the discussion of intentionally entering actions was revised and the GL 87-09 wording of "routine voluntary removal of redundant system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable," was separated from the phrase, "operational convenience," altering the intent in GL 87-09. The draft STS LCO 3.0.3 Bases retained the GL 87-09 wording.

The Maintenance Rule In parallel with the development and issuance of the improved STS, the NRC developed regulations governing maintenance at nuclear power plants. The NRC had been monitoring the performance of on-line maintenance at commercial nuclear power plants and the Commission first voted to produce a maintenance policy statement in April 1987. The Commission issued the "Interim Policy Statement on Maintenance of Nuclear Power Plants," in January 1988. The TSTF believes that this interest in online maintenance is the reason the GL 87-09 Bases were expanded to discuss intentionally removing systems from service and relying on Actions.

TSTF-565, Rev. 1 Page 5 In July 1991, the NRC published the final version of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" (the Maintenance Rule).

Paragraph (a)(3) of the rule stated, in part, "(I)n performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety functions." In 1999, the NRC published a revision to the Maintenance Rule that replaced the quoted sentence in Paragraph (a)(3) with a new Paragraph (a)(4) that requires licensees to assess and manage any increase in risk that may result from proposed maintenance activities, and clarified the applicability of the Maintenance Rule to all modes of plant operation.

In SECY 99-0133, the staff discussed the industry comments on the 1999 Maintenance Rule change (Reference 8). The NRC responded to comments from the Nuclear Energy Institute regarding the intersection of the Maintenance Rule and the TS and stated, in part:

The second NEI concern addressed the apparent overlapping regulatory requirements of technical specifications (TS) and the proposed maintenance rule. The maintenance rule is intended to apply to proposed maintenance activities that will directly, or may inadvertently, result in equipment being taken out of service. Normally, TS may serve as the pre-analyzed assessment, used with sound judgement, when the licensee proposes that a single SSC be removed from service for maintenance when no other SSC is out of service. However, as the licensee proposes that additional SSCs undergo concurrent maintenance, the configuration becomes more complex, and more sophisticated assessment processes are necessary and appropriate.

The staff believes that, in general, TS allowed outage times were not developed for and are inappropriate for controlling concurrent removals of SSCs from service during plant operation. In an October 6, 1994, letter to Mr. Zach T. Pate, President of the Institute of Nuclear Power Operations (INPO), NRC's Executive Director for Operations, James M.

Taylor, stated: "Doing preventive maintenance on more than one train or system at a time can result in plant configurations that, although not prohibited by technical specifications, are detrimental to plant safety." Mr. Taylor also said: "When performing on-line maintenance, confidence in the operability of the independent equipment that is redundant or diverse to the affected equipment should be high." On the same date, in a letter to Mr. Joe F. Colvin, Executive Vice President of NEI, William T. Russell, Director of NRC's Office of Nuclear Reactor Regulation (NRR), wrote: "It is important for licensees to understand that the allowable outage times specified in plant technical specifications are based upon a random single failure in a system and a judgement of a reasonable time to effect repairs before plant shutdown is required. The technical specifications do not address allowable outage times for multiple equipment being taken out of service at the same time." The staff expects that, while performing on-line or shutdown maintenance, the licensee will remain in conformance with its TS. In addition, the licensee's pre-maintenance planning is expected to include, to the depth necessary for the complexity of the maintenance activities, (1) identification of the equipment to be protected during the maintenance activity and (2) contingency plans that identify equipment to be restored first, if necessary, should a random equipment failure occur, and compensatory actions to be taken should the proposed outage duration be exceeded. The revised wording requiring licensees to assess and manage the increase in risk is intended

TSTF-565, Rev. 1 Page 6 to cause the licensee to determine its options and follow a prudent course of action, consistent with the staff's expectations outlined above.

The staff's concerns are reflected in the industry guidance for implementing the Maintenance Rule. NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," is endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Section 11.3.4 of NUMARC 93-01, "Assessment Methods for Power Operating Conditions," states:

Removal from service of a single structure, system, train or component, is adequately covered by existing Technical Specifications requirements, including the treatment of dependent components. Thus, the assessment for removal from service of a single SSC for the planned amount of time (e.g., the Technical Specifications allowed out-of-service time, or a commensurate time considering unavailability performance criteria for a non-Technical Specification high safety significant SSC), may be limited to the consideration of unusual external conditions that are present or imminent (e.g., severe weather, offsite power instability).

Simultaneous removal from service of multiple SSCs requires that an assessment be performed using quantitative, qualitative, or blended (quantitative and qualitative) methods. Sections 11.3.4.1 and 11.3.4.2 provide guidance regarding quantitative and qualitative considerations, respectively.

The relationship between the Technical Specifications and the Maintenance Rule is described on the NRC's website:"1 Before issuance of the maintenance rule, 10 CFR 50.65, in July 1991, technical specifications primarily governed plant operations. They dictated what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The maintenance rule marked the advent of a regulation with significant implications for the evolution for technical specifications. The goal of these technical specifications is to provide adequate assurance of the availability and reliability of equipment needed to prevent and, if necessary, mitigate accidents and transients. The maintenance rule shares this same goal but operates at a more fundamental level with a dynamic and more comprehensive process.

In addition to specifying a process for monitoring the effectiveness of maintenance, including performance and condition monitoring, and for balancing maintenance unavailability and equipment reliability, the maintenance rule requires licensees to assess and manage plant configuration risk that results from maintenance. The maintenance rule has put in place many of the mechanisms, measures, and processes envisioned by staff as needed to enhance the safety impact of technical specifications. Thus, achieving synergy 1 https://www.nrc.gov/reactors/operating/licensing/techspecs/risk-management-tech-specifications.html#effect

TSTF-565, Rev. 1 Page 7 between the static technical specifications and the dynamic maintenance rule is a major aim of the effort to create risk management technical specifications.

The STS LCO 3.0.2 and LCO 3.0.3 TS and Bases were not revised to reflect the promulgation of the Maintenance Rule and the associated guidance that requires an assessment of the increased risk associated with performing maintenance. However, other TS requirements, such as LCO 3.0.4, LCO 3.0.8, LCO 3.0.9, and SR 3.0.3 were revised to take advantage of the risk assessments required by the Maintenance Rule (References 9, 10, 11, and 12).

2.2 Current Technical Specifications Bases The STS LCO 3.0.2 Bases state, in part:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

The LCO 3.0.3 Bases state, in part:

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that 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.

2.3 Reason for the Proposed Change The LCO 3.0.2 and LCO 3.0.3 Bases state requirements or limitations regarding voluntary entry into Actions that are not in the TS. This is inconsistent with the purpose of Bases as described in 10 CFR 50.36. Further, these Bases statements rely on the undefined phrase "operational convenience," which has caused confusion. These statements are not needed because the Maintenance Rule is more effective in ensuring plant safety is maintained when equipment is removed from service. The Bases are revised to reflect the regulatory requirements and endorsed guidance. These revisions will restore consistency between the TS and the TS Bases, reflect the significant regulatory requirements that affect their use, and clarify the proper application of the TS.

TSTF-565, Rev. 1 Page 8 2.4 Description of the Proposed Change The STS LCO 3.0.2 Bases are revised to state (removed words are struck out, added words are in italics):

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

The STS LCO 3.0.3 Bases are revised to state:

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

The proposed change is a change to the TS Bases. The TSTF is requesting that the NRC review and approve the proposal as a change to the Standard Technical Specifications (NUREG-1430 through 1434, and NUREG-2194) to ensure the industry and the NRC are aligned on these important concepts.

Licensees may make the change to the TS Bases in accordance with the Technical Specifications Bases Control Program without prior NRC approval. Therefore, no model application is included in the traveler.

TSTF-565, Rev. 1 Page 9 3

TECHNICAL EVALUATION LCO 3.0.2 Bases Revision The following provides a breakdown of the current LCO 3.0.2 Bases statements followed by a justification why each is either retained, revised, or removed.

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally.

This statement is correct and is retained. The Required Actions are applicable when an LCO is not met; however, regardless if the LCO is not met intentionally or unintentionally.

Reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

This statement is correct but adds no value and is removed. Providing a list of possible reasons, but stating the reasons are not limited to the items on the list, provides no guidance. Further, it implies that there are situations in which the LCO is not met and the ACTIONS do not apply, which is inconsistent with LCO 3.0.2.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety.

This statement attempts to impose a new requirement that does not appear in LCO 3.0.2, which is inconsistent with the purpose of the TS Bases as described in 10 CFR 50.36(a)(1). It is replaced with a new statement.

Intentional entry into ACTIONS should not be made for operational convenience.

This statement attempts to impose a new requirement that does not appear in LCO 3.0.2 and is removed. It is inconsistent with the purpose of the TS Bases, as described in 10 CFR 50.36(a)(1), by attempting to impose requirements in the Bases. LCO 3.0.2 imposes no limitations on entering Actions when the LCO is not met. Further, the NRC has long acknowledged that licensees enter Actions for performing testing, maintenance, and repair at power instead of during a shutdown, and referred to these acceptable activities as "operational convenience."

The original intent of this Bases discussion, added by Generic Letter 87-09, was to state that redundant components should not be routinely removed from service intentionally if other alternatives were available. While it is a worthy sentiment (now codified in the Maintenance Rule), it is inappropriate to place such requirements in the TS Bases.

It should be noted that TSTF-529-A, Revision 4, "Clarify Use and Application Rules," approved by the NRC on April 21, 2016, eliminated references to "operational convenience," from the STS SR 3.0.2 and SR 3.0.3 Bases.

TSTF-565, Rev. 1 Page 10 Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead.

The statement is replaced. The existing Bases statement attempts to impose a new requirement that does not appear in LCO 3.0.2, which is inconsistent with the purpose of the TS Bases as described in 10 CFR 50.36(a)(1). LCO 3.0.2 imposes no limitations on entering Actions when the LCO is not met. The statement also attempts to impose new TS requirements. There are existing TS Actions which apply when redundant components are inoperable and there are no limitations in the TS on intentionally entering such actions.

Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

The statement confuses LCO 3.0.2 and LCO 3.0.3, is incorrect, and is removed. In many cases the TS provide Actions to follow if both subsystems/trains of a safety function are inoperable and LCO 3.0.3 does not apply. These Actions have been determined to be appropriate for the given level of degradation.

The LCO 3.0.2 Bases are revised to include the following discussion:

The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4).

The current Bases discussion focuses on ensuring that intentional entry into Actions does not compromise safety. However, in the context of the existing statement, "safety" is not defined and implies that activities permitted by the TS are prohibited, which is contradictory. The Bases predate and do not recognize the 10 CFR 50.65 requirement to assess and manage risk (using NRC endorsed guidance) when plant systems are removed from service.

The proposed Bases revision is based on NUMARC 93-01, Section 11.3.4, which states:

Removal from service of a single structure, system, train or component, is adequately covered by existing Technical Specifications requirements, including the treatment of dependent components. Thus, the assessment for removal from service of a single SSC for the planned amount of time (e.g., the Technical Specifications allowed out-of-service time

), may be limited to the consideration of unusual external conditions that are present or imminent (e.g., severe weather, offsite power instability).

Simultaneous removal from service of multiple SSCs requires that an assessment be performed using quantitative, qualitative, or blended (quantitative and qualitative) methods.

The proposed Bases discussion has several advantages over the current Bases:

• The Bases are consistent with LCO 3.0.2, in that no new requirements are imposed.

TSTF-565, Rev. 1 Page 11

• The Bases are consistent with the regulations (10 CFR 50.36 and 10 CFR 50.65).

• The Bases are consistent with the TS, in that conflicts with the TS are eliminated.

• The Bases are consistent with NRC-endorsed industry 10 CFR 50.65 implementation guidance (Regulatory Guide 1.160 and NUMARC 93-01).

• The Bases eliminate undefined terms, such as "operational convenience" and "does not compromise safety," and replaces them with industry and NRC-understood guidance.

LCO 3.0.3 Bases Revision The following provides a breakdown of the current LCO 3.0.3 Bases statements followed by a justification why each is either retained, revised, or removed:

It is not intended to be used as an operational convenience that 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.

This sentence is replaced. The current TS Bases attempts to impose a new requirement that does not appear in LCO 3.0.3, which is contrary to the intent of the TS Bases as described in 10 CFR 50.36(a)(1). The TSs clearly state the applicability of LCO 3.0.3 and the Bases go beyond the TS requirements. The TSs have no restrictions that correspond to routine voluntary removal of redundant systems and the TS Bases cannot impose requirements.

The term "operational convenience" is vague and can be interpreted many ways. There is no NRC or industry guidance that distinguishes between acceptable and unacceptable use of LCO 3.0.3. Further, attempts to clarify the meaning of operational convenience would impose TS requirements in the Bases, which is contrary to the intent of the TS Bases as described in 10 CFR 50.36(a)(1).

There is historical precedent to avoid the routine intentional entry into LCO 3.0.3, which typically represents a significantly degraded condition, when there are other alternatives available. The industry agrees with the NRC's 1987 position, "that occasional entry into LCO 3.0.3 for surveillance or maintenance purposes may be appropriate, however, this activity should be well thought out in advance and strictly controlled by management oversight and appropriate procedures." Therefore, the proposed LCO 3.0.3 Bases states:

Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives.

The proposed Bases clearly state the NRC expectations and industry practice that licensees should avoid planned entry into LCO 3.0.3. However, there may be circumstances in which a planned entry into LCO 3.0.3 is the most practicable, lowest-risk alternative. In that case, planned entry is considered acceptable provided that the risk is assessed and managed as required

TSTF-565, Rev. 1 Page 12 by 10 CFR 50.65. The proposed use of "should" does not impose requirements and is consistent with 10 CFR 50.36.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 "Technical Specifications," paragraph (a) requires that the license application include a summary statement of the bases or reasons for the technical specifications, other than those covering administrative controls, but these bases shall not become part of the technical specifications. A licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the Technical Specifications Bases Control Program. The proposed Bases change revises the Bases to provide a more accurate description of the reasons for the associated TS (LCO 3.0.2 and LCO 3.0.3) and, therefore, is compliant with the regulation 10 CFR 50.65 "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," paragraph (a)(4) requires the licensee to assess and manage the increase in risk that may result from proposed maintenance activities before performing those activities. Technical Specification structures, systems, trains, and components are included in the scope as defined in 10 CFR 50.65, paragraph (b). The proposed Bases changes do not adversely impact these requirements, rather, the proposed change adds clarification consistent with 10 CFR 50.65 and associated industry implementation guidance.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) implementation of the proposed Bases changes will not be inimical to the common defense and security or to the health and safety of the public.

5 REFERENCES

1.

U.S. NRC 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," dated June 4, 1987. (NRC ADAMS Accession No. ML031140381)

2.

Memorandum from Brian K, Grimes, Assistant Director for Engineering and Projects, U.S. NRC, to Samuel E. Bryan, Assistant Director for Field Coordination, U.S. NRC, "Clarification of STS: AC and DC Distribution," dated June 13, 1979. (NRC ADAMS Accession No. 790807003)

3.

Letter from J. B. Martin, Regional Administrator, Region V, to Harold R. Denton, Director, Office of Nuclear Reactor Regulation, "Intentional Entry into Technical Specification Limiting Condition for Operation 3.0.3," dated March 18, 1987. NRC ADAMS Accession No. 8704300349)

4.

BWR Owners' Group to U.S. NRC, "BWR Owners' Group (BWROG) Improved BWR Technical Specifications," dated May 5, 1989.

TSTF-565, Rev. 1 Page 13

5.

Westinghouse Owners Group to U.S. NRC, "Westinghouse Owners Group MERITS Program Phase II, Technical Specifications and Bases," dated March 30, 1989.

6.

The B&W Owners Group to the US. NRC, "B&W Owners Group Revised Standard Technical Specifications," dated May 1, 1989.

7.

The Combustion Engineering Owners Group to the U.S. NRC, "C-E Owners Group Restructured Standard Technical Specifications and Bases, CEN-355," May 26, 1989.

8.

SECY 99-0133, "Final Revision To 10 CFR 50.65 to Require Licensees to Perform Assessments Before Performing Maintenance," May 17, 1999. (ADAMS Accession No. ML992810144)

9.

TSTF-358, Revision 6, "Missed Surveillance Requirements," Notice of Availability, 66 Fed. Reg. 49714, September 28, 2001.

10.

TSTF-359, Revision 9, "Increase Flexibility in Mode Restraints," Notice of Availability, 68 Fed. Reg. 16579, April 4, 2003.

11.

TSTF-372, Revision 4, "Addition of LCO 3.0.8 on the Inoperability of Snubbers," Notice of Availability, 70 Fed. Reg. 23252, April 4, 2005.

12.

TSTF-427, Revision 2, "Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY," Notice of Availability, 71 Fed. Reg. 58444, October 3, 2006.

TSTF-565, Rev. 1 Technical Specifications Bases Proposed Changes

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-2 Rev. 4.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:

a.

An associated Required Action and Completion Time is not met and no other Condition applies or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions TSTF-565, Rev. 1

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-4 Rev. 4.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met,

b.

A Condition exists for which the Required Actions have now been performed, or

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach TSTF-565, Rev. 1

LCO Applicability B 3.0 Westinghouse STS B 3.0-2 Rev. 4.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4).The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions TSTF-565, Rev. 1

LCO Applicability B 3.0 Westinghouse STS B 3.0-4 Rev. 4.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met,

b.

A Condition exists for which the Required Actions have now been performed, or

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach TSTF-565, Rev. 1

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-2 Rev. 4.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:

a.

An associated Required Action and Completion Time is not met and no other Condition applies or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions TSTF-565, Rev. 1

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-4 Rev. 4.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met,

b.

A Condition exists for which the Required Actions have now been performed, or

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach TSTF-565, Rev. 1

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-2 Rev. 4.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.10, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions TSTF-565, Rev. 1

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-4 Rev. 4.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met,

b.

A Condition exists for which the Required Actions have now been performed, or

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach TSTF-565, Rev. 1

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-2 Rev. 4.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.11, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered.

Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions TSTF-565, Rev. 1

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-4 Rev. 4.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met,

b.

A Condition exists for which the Required Actions have now been performed, or

c.

ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach TSTF-565, Rev. 1

LCO Applicability B 3.0 AP1000 STS B 3.0-2 Rev. 0 BASES LCO 3.0.2 (continued)

Completing the Required Actions is not required when an LCO is met, or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCOs ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, RCS Pressure and Temperature (P/T) Limits.

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

TSTF-565, Rev. 1

LCO Applicability B 3.0 AP1000 STS B 3.0-3 Rev. 0 BASES LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met, and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies; or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives. It is not intended to be used as an operational convenience that 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.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit 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 capabilities of the unit. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met; TSTF-565, Rev. 1