Text

Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules
	ML18183A343
Person / Time
Site:	Salem, Hope Creek
Issue date:	06/29/2018
From:	Duke P; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LAR H18-03, LAR S18-04, LR-N18-0059
	Download: ML18183A343 (48)
	v • d • e

LR-N18-0059 LAR S18-04 LAR H18-03 June 29, 2018 PSEG Nuclear LLC PO. Box 236, Hancoci{s Bridge, NJ 08038-0236 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 SALEM GENERATING STATION, UNITS 1 AND 2 C PSEG Nuclear LLC 10 CFR 50.90 RENEWED FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 NRC DOCKET NOS. 50-272 AND 50-311

Subject:

HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-57 NRC DOCKET NO. 50-354 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-529, "CLARIFY USE AND APPLICATION RULES" Pursuant to 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for amendments to the Technical Specifications (TS) for Renewed Facility Operating License Nos. DPR-70, DPR-75 and NPF-57 for Salem and Hope Creek Generating Stations respectively.

The proposed amendment would modify TS requirements in Section 3/4.0, "Applicability,"

regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage.

These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF)

Traveler TSTF-529, "Clarify Use and Application Rules." provides a description and assessment of the proposed changes. Attachments 2 and 3 provide the existing TS pages marked up to show the proposed changes. Attachments 4 and 5 provide, for information only, existing TS Bases pages marked to show the proposed changes.

PSEG requests NRC approval of the proposed license amendments in accordance with the standard NRC approval process and schedule, to be implemented within 60 days of issuance.

There are no regulatory commitments contained in this letter.

June 29,2018 Page 2 LR-N 18-0059 10 CFR 50.90 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), PSEG is notifying the State of New Jersey of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 29, 2018 (Date)

Respectfully, C2J~fj~J Paul R. Duke, Jr.

v...... -

-\\

Manager - Licensing Attachments:

1.

Description and Assessment

2.

Proposed Technical Specifications Changes for Salem (Mark-Up)

3.

Proposed Technical Specifications Changes for Hope Creek (Mark-Up)

4.

Proposed Technical Specifications Bases Changes for Salem (Mark-Up)

5.

Proposed Technical Specifications Bases Changes for Hope Creek (Mark-Up) cc:

Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Salem Commitment Tracking Coordinator Mr. T. MacEwen, Hope Creek Commitment Tracking Coordinator

LR-N 18-0059 Description and Assessment

LR-N 18-0059 LAR S18-04 LAR H18-03 SALEM GENERATING STATION AND HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NOS. DPR-70. DPR-75 AND NPF-57 DOCKET NOS. 50-272. 50-311 AND 50-354 License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules" Table of Contents

1.0 DESCRIPTION

.......................................................................................... 2

2.0 ASSESSMENT

2 2.1 Applicability of Safety Evaluation............................................................

2 2.2 Variations............................................................................................ 2

3.0 REGULATORY ANALYSIS

........................................................................... 3 3.1 No Significant Hazards Consideration Analysis............................................ 3

4.0 ENVIRONMENTAL CONSIDERATION

............................................................ 4

5.0 REFERENCES

........................................................................................... 4 Page 1

LR-N 18-0059

1.0 DESCRIPTION

LAR S18-04 LAR H18-03 The proposed change revises Section 3/4.0, "Applicability" of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

Surveillance Requirement (SR) 4.0.3 is revised to allow application of SR 4.0.3 when an SR has not been previously performed and to clarify the application of SR 4.0.3.

2.0 ASSESSMENT

2.1 Applicabilitv of Safetv Evaluation PSEG Nuclear LLC (PSEG) has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016 (Reference 5.2). This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-529 (Reference 5.1). As described in the subsequent paragraphs, PSEG has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC are applicable to Salem Generating Station and Hope Creek Generating Station and justify this amendment for the incorporation of the changes to the Salem and Hope Creek TS.

2.2 Variations PSEG is proposing the following variations from the TS changes described in the TSTF-529, or the applicable parts of the NRC staff's safety evaluation dated April 21, 2016. These variations do not affect the applicability of TSTF-529 or the NRC staff's safety evaluation to the proposed license amendment.

The Salem TS are based on NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors, and, therefore, the wording, numbering and format vary slightly from NUREG-1431, Standard Technical Specifications Westinghouse Plants, shown in TSTF-529, Revision 4, and the applicable parts of the NRC staff's safety evaluation.

Specifically, Salem TS 4.0.3 is the corresponding TS associated with the TSTF-529 changes for STS SR 3.0.3. In addition, the Salem TS do not include a section on Completion Times similar to STS TS 1.3. Hence, the STS TS 1.3 changes included in TSTF-529 are not applicable to this proposal. In addition, the phrase, "unless otherwise specified" is not being added to the Specification 3.0.2 Bases because no minor discrepancy is created between 3.0.2 Bases and TS 1.3 which is not being adopted. Also, Salem TS LCO 3.0.6 is the corresponding TS associated with the TSTF-529 changes for STS LCO 3.0.5 Bases.

The Hope Creek TS are based on NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors, and, therefore, the wording, numbering and format vary slightly from NUREG-1433, Standard Technical Specifications General Electric BWR/4 Plants, shown in TSTF-529, Revision 4, and the applicable parts of the NRC staff's safety evaluation.

Specifically, Hope Creek TS 4.0.3 is the corresponding TS associated with the TSTF-529 changes for STS SR 3.0.3. In addition, the Hope Creek TS do not include a section on Completion Times similar to STS TS 1.3. Hence, the STS TS 1.3 changes included in TSTF-529 are not applicable to this proposal. In addition, the phrase, "unless otherwise specified" is Page 2

LR-N18-0059 LAR S18-04 LAR H18-03 not being added to the Specification 3.0.2 Bases because no minor discrepancy is created between the 3.0.2 Bases and TS 1.3 which is not being adopted.

These minor variations are administrative and do not affect the applicability of TSTF-529 to the Salem and Hope Creek TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis PSEG Nuclear LLC (PSEG) requests adoption of TSTF-529 "Clarify Use and Application Rules," that is an approved change to the Standard Technical Specifications (STS), into the Salem and Hope Creek Technical Specifications (TS). The proposed change revises Sections 3.0, "LCO Applicability," and 4.0 "SR Applicability," of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 4.0.3. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 4.0.3 is revised to allow application of SR 4.0.3 when an SR has not been previously performed.

PSEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No.

The proposed changes to LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 4.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes do not significantly affect system Operability, the proposed changes will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

TherefOre, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 3

LR-N18-0059 LAR S18-04 LAR H18-03

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the application of LCO 3.0.4 and does not result in changes in plant operation. SR 4.0.3 is revised to allow application of SR 4.0.3 when an SR has not been previously performed and there is reasonable expectation that the SR will be met when performed. This expands the use of SR 4.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

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

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

5.0 REFERENCES

5.1 TSTF-529, Revision 4, "Clarify Use and Application Rules," dated April 25, 2016 5.2 Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-529, Revision 4, "Clarify Use and Application Rules," Using the Consolidated Line Item Improvement Process (TAC NOS. MF1406 AND MF1407), dated April 21, 2016 Page 4

LR-N 18-0059 Proposed Technical Specifications Changes {Mark-Up)

For Salem Units 1 and 2

LR-N 18-0059 LAR S18-04 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)

The following Technical Specifications for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification 3.0.4 4.0.3 3/4 0-1 3/4 0-3 The following Technical Specifications for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification 3.0.4 4.0.3 3/4 0-1 3/4 0-3

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals.

If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

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

1.

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

2.

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

3.

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

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

Exceptions to these requirements are stated in the individual specifications.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if

---EDCBA@?exceptions to this Specification are stated in the

_pecifications7r

[]

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SALEM -

UNIT 1 3/4 0-1 Amendment No.

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of

the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified frequency shall be failure to meet the Limiting Condition for Operation, except as provided in Specification 4.0.3. Surveillances do not have to*be performed on inoperable equipment or variables outside specified limits.

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

4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.11 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and thE\\ "risk impact shall be managed.

If the Surveil! nee is not performed within the delay period, the Limiting Condition for Operation must immedia ely be declared not met and the applicable Actions must be entered.

When the Sun eillance is performed within the delay period and the Surveillance is not met, the Limiting Condi *on for Operation must immediately be declared not met and the applicable Actions must b p entered.

4.0.4 Entry intc a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision sr F3ll not prevent entry into MODES or other specified conditions in the Applicability that re required to comply with ACTIONS or that are part of a shutdown of the unit.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

SALEM - UNIT 1 3/4 0-3 Amendment No.

3i4.0 APPLICABILITY LIMITING CONOITION FOR OPERATION 3.0.1 Compliance with the limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Qperation and associated ACTION requirements are not met within the specified time intervals.

If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

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

1

At l eat;t HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2.

At lea s t HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3.

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

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

Exceptions to these requirements are stated in the individual specifications.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appr9:;=<=exceptions to this Specification are stated in the individual Spec

_s, 8

c.

Wnen an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a

shutdown of the unit.

SALEM UNIT 2 3/4 0-1 Amendment No.

APPLICABILITY i

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or ather specified conditions in the Applicability far individual Limiting Conditions far Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition far Operation. Failure to perform a Surveillance within the specified frequency shall be failure to meet the Limiting Can:ditian far Operation, except as provided in Specification 4.0.3. Surveillances do nat have to be performed an inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension nat to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was nat performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition far 9peratian :nat met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. +..A risk evaluation shall be performed for any Surveillance.delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and th *risk impact shall be managed.

If the Surveil ance is nat performed within the delay period, the Limiting Condition for'Operatian must immed ately be declared-nat met and the applicable Actions must be entered.

When the S l.rrveillance is performed within the delay period and the Surveillance is n()t met, the Limiting Co ditian far Operation must immediately be declared nat met and the appliable Actions mu t be entered.

1 4.0.4 Entr into a MODE or ather specified condition in the Applicability of an LCO shall only be made whe h the LCO's Surveillances have been met within their specified Frequency,' except as provided t y SR 4.0.3. When an LCO is nat met due to Surveillances nat having been met, entry into a MO bE or ather specified condition in the Applicability shall only be made in acardance with LCO 3. 0.4.

This pro' rsian shall nat prevent entry into MODES or ather specified conditions in the Applicab lity that are required to comply with ACTIONS or that are part of a shutdown of the unit.

L The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

SALEM-UNIT 2 3/4 0-3 Amendment No. Ye

LR-N 18-0059 Proposed Technical Specifications Changes (Mark-Up)

For Hope Creek

LR-N 18-0059 LAR H18-03 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)

The following Technical Specifications for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification 3.0.4 4.0.3 3/4 0-1 3/4 0-3

3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, and except as provided in LCO 3.0.8.

3.0.2 Noncompliance with a

Specification shall exi st when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals.

If the Limiting Condition for Operation is restored prior to expiration of the speci fied time intervals, completion of the Action requi rements is not required.

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

1.

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

2.

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

3.

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

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

Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in OPERATIONAL CONDITIONS 4 or 5.

3.0.4 When an LCO is not met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the OPERATIONAL CONDITION or other specified condition in the Applicability for an unlimited period of time; or

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL CONDITION or other specified condition in the Applicability, and establishment of risk management actions, if approp6543exceptions to this Specification are stated in the individual cations7 7

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

HOPE CREEK 3/4 0-1 Amendment No.

2

APPLICABILITY SURVEIL4'NCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.

Failure to rform a Surveillance within the specified frequency shall be a failure to meet the Limiting caf,dition for Operation, except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

1 4.0.2 Each Surveillance Requirement shall be performed within its specified surveillance interval wit a maximum allowable extension not to exceed 25 percent of the specified surveillanca interval.

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

If the Su illance is not performed within the delay period, the Limiting Condition for Operation must im iately be declared not met and the applicable Actions must be entered.

l When t e s,urveillance is performed within the delay period and the Surveillance is not met, the Limiti Condition for Operation must immediately be declared not met and the applicable Actio s mut be entered.

I 4.0 Entr}{ into an OPERATIONAL CONDITION or other specified condition in the Applicability of n LCO shall only be made when the LCO's Surveillances have been met within their s ecified Ff:equency, except as provided by SR 4.0.3. When an LCO is not met due to urveillancs not having been met, entry into an OPERATIONAL CONDITION or other pacified cqndition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provisfon shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions ip the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

I HOPE CR EK 314 0-3 Amendment No. 485

LR-N18-0059 Proposed Technical Specifications Bases Changes (Mark-Up)

For Salem Units 1 and 2

LR-N 18-0059 LAR S18-04 PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UP)

FOR INFORMATION ONLY The following Technical Specification Bases for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification Bases Page B 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4a B 3/4 0-6 B 3/4 0-7 The following Technical Specification Bases for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification Bases Page B 3/4 0-2 B 3/4 0-3 B 3/4 0-3a B 3/4 0-4a B 3/4 0-6 B 3/4 0-7

1\\PPLICAB!;.ITY BASES specification 3.0.2 establishes that noncompliance with a specification exist.

when the requirements of the Limiting Condition for Operation are not mat and the associated ACTION requirements have not bean implemented within the specified time interval.

The purpose of this specification is to clarify that

. (l) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.

Spteification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not mat and the condition is not specifically addraaad by the associated ACTION requirements.

The purpose of this specification is 'to delineate the time imita 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 ita 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 baing inoperable.

one hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation.

This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid.

The time limits specified to MODES of operation permit the shutdown to proceed in a controlled and or manner that is wall within the specified maximum cooldown rata and within cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE.

This reduces thermal str***** on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated.

The time limits of the ACTION requirements are applicable from the point in time there was a failure to meat a Limiting condition for Operation.

Therefore, the shutdown may be terminated if the ACTION requirements have bean m or the time limits of the ACTION requirements have not expired, thus provi g an allowance for the completion of the required action, the LCO is no longer applicable, entered The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for t a the COLD SHUTDOWN MODE when a shutdown is required during t e operation.

If the plant is in a lower MODE of operation w an a shutdown is

required, the time limit for *achLRg the next lower MODE f operation applies.

However, if a low MODE of operation is in lass time than

allowed, the total allowa e time to COLD SHUTDOWN, or other applicable

MODE, is not reduced.

F r example, HOT STANDBY is aaahad in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach T SHUTDOWN is the next 11 h

because of the total time to allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

Therefore, would permit SALEM -

UNIT l Amendment No. -lJ.l I

I I

I

- 'I I

r-

/.-----,

APPLICABILITY BASES return to POWER operat.ion, a penalty is not incurred by having to ';l;;ea.s.a.

lower MODE of operation in less than the total time allowed.

The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met.

If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification.

However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 do not apply in MODES 5 and 6,

because the ACTION requirements of individual specifications define the remedial measures to be taken.

either entered the MODE or other specified condition in the Applicability r an unlimited period of time.

Compliance with Reqairea Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation.

This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made LCO a

ows en ry 1n o a or o er spec1 1e con 1 1on in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions,

--- if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a) (4),

which requires that risk impacts of maintenance activities to be assessed and managed.

The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a) (4) risk assessment scope.

The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.1 82, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.1 82 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management

actions, and example risk management actions.

These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management SALEM -

UNIT 1 B 3/4 0-3 Amendment No. 2-+6-

Insert 1 For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

APPLICABILITY BASES personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions.

The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time.

Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above.

However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited.

The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on an ACTION in the Specification which states LCO 3.0.4.c is applicable.

These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed.

This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components.

For this reason, LCO 3.0.4.c is typically applied to Specifications that describe values and parameters (e.g.,

Ceaaiamea PEessEe, MGaeEaeE 1/41/23/4¿),

and may be applied to other Specifications based on NRC plant-specific appr

1. RCS Specific Activity The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and SALEM - UNIT 1 B 3/4 0-3a Amendment No.6+&

APPLICABILITY BASES Specification 3.0.6 establishes the allowance for restoring equipment to service under administrative control s when it has been removed from service or declared inoperable to comply with ACTIONS.

The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g.,

to not comply with the applicable Required Action(s))

to allow the performance of testing required to restore and demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the testing required to restore and demonstrate the operability of the equipment.

This Specification does not provide time to perform any other preventive or corrective maintenance.

II nsert 2 1-l ->

An e3Eample ef demonstrating the OPE\\BILITY ef the equipment being returned te service is reopening a containment isolation vale that has been closed to eemply 'lt'ith Required,",ctiens and must be reopened to perform the testing required te restore and demonstrate OPERABILITY.

)

An example of demonstrating the OPERABILITY of other equipmen is taking an inoperable channel or trip system out of the tripped conditio to prevent the trip function from occurring during the performance of testing required to restore OPERABILITY o another channel in the other tip system, A similar SALEM UNIT 1 B 3/4 0-4a Amendment No.

Insert 2 LCO 3.0.6 should not be used in lie u of other practicable alternatives that com ply with Req uired Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate eq uipment is OPERABLE. LCO 3.0.6 is not intended to be used repeatedly.

An example of demonstrating equipment is O PERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Req uired Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressu re Isolation Valve (PIV) leakage in o rder to perform testing to demonstrate that RCS PIV leakage is n ow within limit.

Examples of demonstrating equ ipment OPERABI LITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Req uired Action, if there is no Req uired Action Note for this purpose. An example of verifying OPERABI LITY of equ ipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the a ppropriate response d uring performan ce of required testing on the inoperable channel. Examples...

Insert 3 The administrative controls in LCO 3.0.6 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realig n ment or reposition ing of redu ndant or alternate equipment or trains previously manipulated to comply with ACTIO N S, as well as eq uipment removed from service or declared inoperable to comply with ACTIONS.

APPLICAB IL I TY BASES the equ i pment is not otherwi s e bel i eved to be incapab l e of per forming i ts func t i on. Thi s wi l l a l l ow ope ra t i on t o proceed t o an O PERATI ONAL MODE or o ther spec i f i ed condi t i on where other nece s s ary pos t maintenance t e s t s can be c omp l e t ed.

Some examples o f thi s proc e s s are :

a. Auxi l i ary Feedwa t e r

( AFW )

pump turbine ma int enanc e dur ing re fuel ing that requires tes t ing at s team pres sures 6 8 0 p s i g.

However,

if o ther appropr i a t e t e s t i ng is s a t i s fac t o r i ly c omp l e ted,

the AFW sys t em can be c ons i dered O PERABLE.

Thi s a l l ows s tartup and other nece s s ary tes ting to proceed unt i l the plant reaches the s team pre s s ur e required to per form the t e s t ing.

b. High Pressure S a f e ty Inj ec t i on

( HPi l ma intenanc e dur ing s hutdown that requ i res sys tem func t i ona l t e s t s at a spec i f i ed pres s ure.

Provi ded o ther appropr i a t e tes t ing is s a t i s factori ly c omp l e t ed,

s tartup can proceed wi th HPI c ons i dered OPERABLE.

Thi s a l l ows opera t i on to reach the spec i f i ed pres sure to comp l e t e the nece s sary p o s t maintenance t e s t ing.

Spec i f ic a t i on 4. 0. 2 e s tabl i shes the l imi t for whi ch the spec i f i ed t ime interval for Surve i l l anc e Requ i r ements may be extended.

I t permi ts an a l l owab l e extens i on o f the normal surve i l l ance interval to fac i l i ta t e surve i l l ance s chedu l ing and c ons i dera t i on o f p l ant operat ing c ondi t i ons that ot be sui tabl e for c ondu c t ing the s urve i l l anc e ;

e. g., trans i ent ons or other ongoing surve i l l ance or maintenance a c t ivi t i es.

I t a l s o s f l exibi l i ty to accommoda te the l ength o f a f u e l cyc l e for l l anc e s tha t are performed a t each r e fuel ing outage and are spec i f i ed th an 1 8 month surve i l l anc e interval.

It i s not intended that thi s provi s i on b e used repeatedly as a eeaveaieaee to extend surve i l l ance interva l s beyond tha t spec i f i ed for surve i l l ance s tha t are not per f ormed during refuel ing outages.

The l imi t a t i on o f Spec i f i ca t i on 4. 0. 2 i s based on eng ineer ing j udgment and the recogni t i on that the mos t probabl e resul t of any par t i cu l ar surve i l l ance be ing per formed is the ver i f i cat i on o f conformance wi th the Surve i l l ance Requ i r emen t s.

Thi s provi s i on is s u f f i c i ent to ensure that the rel iabi l i ty ensured through survei l l ance act ivi t i es i s not s i gni f i cantly degraded beyond that obtained from the spec i f i ed survei l lance int erva l.

performed Spec i f i ca t i on 4. 0. 3 e s t abl i shes the f l exibi i ty to de fer dec l a ring a f fected equipment inoperabl e, or an a f f e c t e d vari le out s i de the spec i f i ed l imi t s,

when a Survei l l ance has not been eempleted wi thin the spec i f i ed frequency.

A del ay per i od o f up to 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months o r up to the l imi t o f the spec i f i ed frequency,

whi chever i s grea t e r,

app l i es f r om the point in t ime that i t i s di s c overed tha t the Surve i l l ance has not been performed in accordance wi th TS 3. 0. 2, and not at the t ime that the spec i f i c feaw::mcy was not met. performance

!Perform 1:;

Thi s del ay per i od provide s adequa e me to eemplete rve i l l ances that have been mi s s ed.

Thi s del ay period permi ts the eempleeiea o f a Survei l l ance be fore c omplying wi th Requi red Ac t i ons or other remedial measures that might pre c lude eempletiea f

nee.

performance The bas i s for t s e ay r i od inc l udes c ons i de ra t i on o f uni t condi t i ons,

adequa t e planning,

avai l abi l i ty o f pers onne l,

the t ime requ i red to perform the Surve i l l anc e,

the s a f e ty s igni f i cance o f the del ay in c omp l e t ing the requ i red Surve i l l anc e,

and the recogni t i on tha t the mos t probable resul t of any part i cular Surve i l lance being per formed is the ver i f i ca t i on o f conformance wi th the requ i r ements.

SALEM -

UNIT 1 B 3 / 4 0 - 6 Amendment No. 266

APPLICABILITY BASES When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e. g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions,

etc. ) is discovered to not have been performed when specified, SR 4. 0. 3 allows for the ful l delay period of up to the specified Frequency to perform the Surveil lance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 4. 0.3 provides a time limit for, and allowances for the performance of,

Surveillances that become applicable as a consequence of MODE changes imposed by Requi red Acttons.

!Insert 4 Failure to comp y with specified frequenc¹es for Surve¹llances ¹s expected to be an infrequent occurrence. Use of the delay period established by

R is a flexibility which is not intended to be used as aa operatisaal repeatedly eoavenieaee to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or e

limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR50. 65 (a) (4) and its implementation guidance, NRC Regulatory Guide 1.1 82,

'Assessing and Managing Risk Before Maintenance Activities a t Nuclear Power Plants. '

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds,

and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide, The risk evaluation may use quantitative,

qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveil lances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee 1 s Corrective Action Program.

If a Surveillance is not completed-- within the allowed delay period, then the. ".

equipment is considered inoperable, or the variable is considered outside the specified limits, and the Completion Times of the Required Actions for the applicable LCO begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits, and the Completions Times of the Required Actions for the applicable LCO begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the Actions, restores compliance with SR 4.0. 1.

SALEM - UNIT 1 B 3/4 0-7

ºmendment No. >>

Insert 4 SR 4.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has eve r been perfo rmed, a n d a n y other indications, tests, or activities that mig ht support t h e expectation that the S urveillance will be met when performed. An example of the use of S R 4.0.3 would be a relay contact that was not tested as required in accord ance with a particular SR, but previous successful perfo rmances of the S R included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated eq uipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been perfo rmed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a hig h degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

APPL ICAB U. I TX

!>=?= * * * * ** = = = z * * = = = * = = = * = = = =.,. = = = = * = = = = = = = = = * = * * * * = * - * = *a = = = = = = = = = = = = = = = = = = = =*;;,*

spee i f i cttien 3. 0. 2 establ ishes t hat noncomp l i ance with a spec i f icat ion ex i s t s 1

when the requ irement s of t he Limit ing cond ition for operat ion are. not met and 1

the assoc iated ACTION requ irement s have not been implemented within t he 1

spec i f ied t ime interva l.

The purpose o f t h is spec i f icat ion i a to c l ar ify that 1

( l ) imp lementat ion o f t he ACTION requ irements w ithin the speø i f ied t ime 1

interval const itutes compl iance with a spec i f ication and

( 2 ) comp let ion of the 1

remedial mea sures of the ACT ION requ irements i s not required when comp l iance 1

with a Limiting Condit ion of Operat ion is restored within the time interva l 1

spec i f i ed in the assoc iated ACTION requi rement*.

1 I

Specif icat ion 3. 0. 3 establishes the shutdown ACT ION requ irement s that must be 1

implemented when a Limiting Condit ion for Operation is not mat and the 1

condit ion i s not spec i f ical ly addres sed by the assoc iated ACTION requ irement s.

1 The purpo se o f this spec i f ic at ion is to de l ineate the time l imite fo plac ing 1

the unit in a safe shutdown MOO! when pl ant operat ion c annot be maint ained 1

w ithin the l imit s fo safe oper at ion def ined by the Limit ing Conditione for 1

Operat ion and it s ACTION requ irement s.

I t is not intended to be ueed as an I

I opertt ional convenience which permits ( routine )

vo luntary removal of redundant 1

system* or components from serv ice in l ieu o f other alternat ive* that would 1

not re sult in redundant systems or component s beinq inoperable.

on* hour i a 1

al lowed to prepare for an orde r ly ehu1:,down before init iat ing a change in plant 1

operat ion.

Thie t ime permits the operator to coord inate the reduct ion in 1

e lectr ical generation with the load dispatcher to en1ure the stab il ity and..

availab i l ity of the e lectrical grid.

The time limitl 1pec i f ied to low*

MOOES o f operation permit the shudown to proceed in a control led d order ly manner that i1 well within the specif ied max imum cooldown rate and ithiri the 1

coo ldown capab il it iee o f the fac i l ity aesuming only the minimum e I

equipment is OPERABLE.

This reduces thermal stres1es on components 1

pr imary coo l ant system and the potent ial for a plant upset that eou 1

chal lenge 1afety eystems under condit ione for which this spec if icat I

appl ies *

, the LCO is no longer applicable, j

I t remedial meuures permit ng l imited cont inued operat ion of the facility I

under the provi1 ion1 of the ACTION requ irement* are completed, the shutdown I

may be terminated.

The t im l imite of the ACTION requirements are appl icable I

from the point in time the was a failure to meet a Limit ing Condit ion for I

Operat ion.

Therefore,

the shutdown may be terminated if the ACT ION I

requir... nts have been met or t he t ime limits of the ACTION requ irement s have I

not exptred, thus providing an a l l owance for the completion o f the required I

actions.

entering entered entered I

I allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for th I

red during th I

operat ion.

I f the plant i rat ion whe a 1hutdown is I

requ ired, the t ime r MODI of perat ion I

appl ies.

However,

if a lower MOOE operation i

aehed in leea time than I

al lowed, the total a l lowable time to COLD SHUTDOWN,

or ther appl icacl*

I MODI,

is not reduced.

ror example, if HOT STANDBY is seaebed in 2 houri, the I

t ime al lowed to reach HOT SHUTDOWN i* the next 11 hour* beeau*e o f the total

time to reach HOT SHUTDOWN is not redu ced from the al lowable limit o f 13 houri.

There fore,

i f remedial measures are completed that wou ld permit a I

SALEK UNIT 2 B 3 / 4 0-2 Amendment No. 1-W

AP PLICABI LITY BASES re turn to POWER operation,

a p enalty is not incurred by having of operation in l e s s than the total time all owed.

renter!

to =oh a lower MODE The s ame principle appl i e s wi th regard to the allowabl e outage time limi ts o f the ACTION requi rements,

if compliance wi th the ACT ION requirements for one speci fi cation results in entry into a MODE or condi tion of op e ration for anothe r speci fication in whi ch the requirements of the Limiting Condi tion for Opera tion are not me t.

I f the rtew /peci :l:i catlon becomes appli cable in l e s s time than specified, the di f ference may be added to the allowable outage time limits o f the s econd speci fication.

However; the allowabl e outa ge time limits of ACTION requi rements for a higher MODE of opera t i on may not be u s ed to extend the allowable outage time that i s applicab le when a Limi ting Condi tion for Operation i s not met in a lower MODE o f operation.

The shutdown requirements o f Specification 3. 0. 3 do not apply in MODES 5 and 6,

becaus e the ACTION requirements o f indi vidual speci fi cations de fine the remedi a l mea s ures t o be t aken.

Speci fi cation 3. 0. 4 establishes limitations on changes in other speci fi ed conditions in the Appli cability when an LCO is not met.

It allows placing the unit in a MODE or other speci fied condition stated in that Appli c bil i t y

( e. g.,

the Appli cability de sired to be entered )

when unit conditions a

s uch that the requi rements of the LCO would not be met, in a ccordance with LCO 3. 0. 4. a,

LCO en ry n o a o r o

e r spec e

con on n e

LCO not met when the a s soci ated ACTIONS to be entered the MODE or other speci fied condition in the Appl i cability an unlimited period o f time.

Comp l i ance with Required Actions at pe rmit continued ope rati on of the uni t for. an unl imited period of t ime in a MODE othe r spe ci fied condi tion provides an acceptable l evel o f s a fety for continued op er ion.

Thi s i s without regard t o the status o f the uni t be fo re or a fter the MODE chan There fore,

in s u ch cas es,

ent ry into a MODE or other speci fied condition in the App ability r----..,., may be made r:A....::C:-::T=-=1-=0ON-:-:S::-\\

dlnsert 1 f.;;,.

and the Required Actions followed after entry into the Applicability LCO 3. 0. 4. b all ows entry into a MODE or other speci fi ed condition in the Appli cability with the LCO not met a fter performance of a ri s k a s s e s sment addre s s ing inoperable s ystems and component s, cons ideration of the re sults, determinati on of the accept ability of ent e ring the MODE or o ther specified condi tion in the Applicab ility, and e s tablishment o f ri s k management a ctions,

if app ropriate.

The risk a s s e s sment may u s e quantitative,

qua l itative,

or blended appro a ches,

and the ris k assessment wi ll be conducted using the plant program, procedures, and criteria in place t o implement 10 CFR 5 0. 65 ( a ) ( 4 ),

which requires that ri s k impacts o f maint enance a ctivi ties to b e a s s e s s ed and managed.

The ris k a s s e s sment,

f o r the purpos es of LCO 3. 0. 4. b, mus t take into account all inoperable Techni cal Speci fi cation equipment regardl e s s of whethe r the equipment is i n cl uded in the normal 1 0 CFR 5 0. 6S ( a-) ( 4 ) ri s k as s e s sment s cope.

The ri s k a s s es sments wi ll be conduct ed us ing the procedures and guidance endo rs ed by Regulatory Guide 1. 1 8 2, "As s es s ing and Managing Ri s k Before Maintenance Acti vities at Nuclear Powe r Plant s. " Regulatory Guide 1. 1 8 2 endorses the guidance in S ection 1 1 o f NUMARC 9 3 - 0 1,

" Indus t ry Gui deline for Monitoring the Effectivene s s of Maintenance at Nu clear Powe r Plant s. "

The s e documents addres s general gui dance f o r conduct o f the ris k a s s e s sment,

quantitative and. qualitative guidelines for e s tabl i s hing ris k ma nagement act i ons, and example ris k management actions.

The s e incl ude a cti ons t o pl an and condu ct other activities i n a manne r that cohtrol s overall ris k, increas ed ri s k awa rene s s by s hi ft and management SALEM -

UNIT 2 B 3 / 4 0- 3 Amendment No.

2-§.8

Insert 1 For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

Al?PLI:CABILITY BASES pers onne l, acti ons to reduce the duration o f the condi t i o n, a ct ions to minimi ze the magnitude of ri s k increas es

( e s t abli s hment of backup s u cce s s p aths or compensatory me asures ), and determination that the p ropo s ed MODE change i s a cceptab l e,

Cons idera tion s hould also be given to the p robab i lity o f comp l eting res t.oration such that. the requirements of the LCO would be met pri o r to the expi ration o f ACTIONS Completion Times that would requi re exiting the Applicability.

LCO 3. 0. 4. b may : be used with s ingle, o r mul tipl e systems and components unavailable.

NUMARC 93-01 p rovide s guidance relat.ive to cons ideration o f s imultaneous unavailability of mul tipl e s ys t ems and component s.

The results of the ris k a s s e s sment s hall be considered in det e rmining the acceptability of entering the MODE o r other speci fied condition in the Applicabi li ty,

and any corresponding ri s k management actions.

The LCO 3. 0. 4. b ri s k a s s e s sment s do not have to be do cument ed,

The Technical Speci fi cations allow continued ope r ati on with equipment unavailable in MODE 1 for the duration of the Comple tion Time.

Since this is allowable,

and since in general the *ri s k impact in that parti cular MODE bo unds the ri s k o f tran s i tioning into and through the appli cable MODES or other speci fied conditions in the Applicability of the LCO,

the us e o f the LCO 3. 0. 4. b allowance should be generally acceptabl e,

a s lang a s the ris k i s a s s es s ed and managed a s s tated ab ove.

Howeve r,

there

is a small sub s e t o f s ys tems and component s that have b een determined to be more important ;o ris k and se of the LCD 3. 0. 4. b allowance is prohibited,

The LCOs governing these* sys tem and coinponents contain Notes p rohibiting the u s e

of LCO 3. 0 *

. 4. b by stating that LCO 3. 0. 4. b is not appli cabl e,

LCO 3 0. 4. c all ows enty into a MODE o r other speci fied condi tion in the Applipab ility with the LCO not met b aa ed on an ACTI ON in the Spe ci fi cati on whi ch s tates LCD 3. 0 ; 4. c is app l i cable.

Thes e speci fi c all owance s permit entry into MODES o r other speci cied conditions in the Applicability when the a s s ociated ACT IONS to be entered do not, p rovide for continued ope ration for an unlimited pe ri od of time and a ris k as s e s sment has not been performed.

This allowance may apply to all the ACT I ONS o r to a specific Requi red Action of a Spe ci fication. The ri s k a s s es sments performed to justify the use o f LCO 3. 0. 4. b usually only cons ider systems and components.

For thi s reason, LCO 3, 0. 4, c is typi cally app l i ed to Speci fi cations tha t des cribe values and

parameters

( e. g.,

Containment Air !emperature,

Containment Pressure, !ederateE me),

and may be app l ied t o other Spe ci fi cations bas ed on NRC pl ant-speci fi c : approvai RCS Specific Activity The p rovi s ions o f thi s Spe cifica tion should not be interpret ed as endors ing the failure to exercis e the good p ractice o f re sto ring systems o r comp onents t o OPERABLE s ta tus be fore entering an as s o ciated MODE or other speci fied condition in the Applicability,

The. provis ions o f LCD* 3. 0. 4 shall not prevent changes in MODES or other speci fied conditions in the Applicabi l ity that are requi red to comp ly with ACTIONS.

In addition,

the p rovi s ions o f LCO 3. 0. 4 s hall not prevent changes in MODES o othe r specified conditions in the Applicability that res ult from any uni t shutdown.

In this context,

a unit shutdown is de fined as a

change in MODE o r o ther specified condition in the Applicability a s s ociated with trans itioning from MODE 1 t o MODE 2,

MODE 2 t o MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry i nto a MODE o r o ther sp e c i fi ed condi tion in the Appli cability with the LCO not met, LCO 3*, 0. 1 and LCO 3. 0. 2 require entry into the applicab l e Conditi ons and SALEM UNIT 2*

B 3 / 4 0-3a Amendment No.

2-§-8

APPLICABI L I TY BASES Speci f ication 3. 0. 6 es t ab l i shes the a l l owance f o r res t o r ing equ i pment to s ervice under admini s t ra t ive contro l s when it ha s been removed from serv i c e or dec lared inoperable t o comply wi th ACTIONS.

The s o l e purpose o f th is Specificat ion i s to provide an exc ep t i on to LCO 3. 0. 2 ( e. g.,

to n o t comp ly wi th the app l i c able Required Ac t i on ( s ) )

t o allow the performance of tes t ing required to res t o re and demonstrate :

a.

The O PERABIL ITY o f the equipmen t be ing r e turned to s e rvi c e ;

o r b.

The OPERAB ILITY o f o ther equ ipment.

The administrat ive contro l s ensure the t ime the equ ipment is re turned t o s erv ice in confl ict wi th t h e requ i rements of the ACTIONS i s l imi ted t o the time abs o lutely necess ary to per form the t e s t ing requ i red to res t ore and demons trate the operabi lity o f the equi pment.

Thi s Spec i f i c a t i on does not provide t ime to perform any other preventive or correc tive maintenance.

!Insert 21-j

)

An example ef demenstratinA the OPB\\OILIY ef the eqtlipment bein retutned to ser wice is reepenin§ a containment iselatien val v e that has been closed to compl::J; wi th Required Actions and: 1\\'ti:!St be reopened to perfont the testing required to t eseere and demenstraee OPERABILI'PY.

2

An example o f demons trat ing the OPERABILITY of other equ GHIJK1 ho! taking an inoperable channe l or trip sys t em out o f the tr ipped c ondi t i on to prevent the trip func t ion from occurr ing during the per formance of tes t ing required to res tore OPERAB ILITY of another channel in the o ther trip sys tem`

A simi lar SALEM UNIT 2 B 3 / 4 0 - 4 a Amendment No.

Insert 2 LCO 3.0.6 should n ot be used in lieu of other practicable alternatives that comply with Req u i red Actions and that do not requ i re changing the MODE or other specified conditions in the Applicability in order to demonstrate eq uipment is OPERABLE. LCO 3.0.6 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions n ot met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressu re Iso lation Valve (PIV) leakage in o rder to perform testing to demonstrate that RCS PIV leakage is n ow with in limit.

Examples of demonstrating equ ipment OPERAB I LITY include instances i n which it is necessary to take an inoperable chan nel or trip system out of a tripped condition that was directed by a Req u i red Actio n, if there is n o Requ i red Action N ote for this purpose. An example of verifying OPERABI LITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples...

Insert 3 The administrative controls i n LCO 3.0.6 apply in all cases to systems or components i n Chapter 3 of the Techn ical Specifications, a s long a s the testing could not be conducted while complyin g with the Required Actions. This includes the real ig nment or repositioning of redu ndant o r alternate eq uipment or trains previously manipulated to comply with ACTIONS, as well as eq u ipment removed from service or declared inoperable to comply with ACTIONS.

APPLICABILITY BASES the equipment is not otherwise believed to be incapable of per forming its function.

This will allow operation to proceed to an OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be:

completed.

Some examples of this process are:

a. Auxiliary Feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures

> 680 psig.

However, if other appropriate testing is satisfactorily completed,

the AFW system can be considered OPERABLE.

This allows startup and other necessary tes ting to proceed until the plant reaches the steam pressure required to perform the testing.

b. High Pressure Safety Injection (HPI) maintenance during shutdown that requires system functi onal tests at a spec ified pressure.

Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE.

This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

Specification 4.0.2 establishes the limit for which the specified time interval for surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g.,

transient conditions or other ongoing surveillance or maintenance a.ctivities.

It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18 month surveillance interval.

It is not intended that this provis ion be used repeatedly as a ee'eHieaee to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages, The limitation of Specification 4.0.2 is based on engineering judgment and the recogni tion that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.

This provision is sufficient to ensure that the reliabili ty ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

performed Specification 4.0.3 establishes the flexibi ity to defer dec laring affected equipment inoperable, or an affected varia e outside the specified limits, when a Surveillance has not been completed ithin the specified frequency.

A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with TS 3.0.2, and not at the time that the specif' ency o

met.

perform performance This delay period provides adequa e me t rve Z ances that have been missed. This delay period permits the eompleeioa of a Surveillance before complying with Required Actions or other remedial measures that might preclude eemeTe*enf s

e.

performance The basis for t s e ay period includes consideration of unit conditions, adequat e planning, availability of personnel,

the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the requirements.

SALEM UNIT 2 B 3/4 0-6 Amendment No. 'l:J7.

APPLICABILITY BASES When a Survei l l ance wi th a Frequency based no t on t ime interval s, bu t upon speci fied uni t condi tions,

operating s i tuat ions,

or requi r ement s o f regulations

( e. g.,

prior to entering MODE l a fte r each fuel l oading,

o r in accordance wi th 1 0 CFR 5 0,

Appendix J, as modi f i ed by approved exemptions,

etc. ) is di s c overed to not have been performed when speci f ied,

SR 4. 0. 3 a l lows for the ful l delay period o f up to the spec i f i ed Frequency to perform the Surve i l l anc e.

Howeve r,

s inc e there i s not a t ime interval speci fied,

the mis s ed Surve i l lanc e should be performed at the f i rs t reasonable oppor tuni ty.

SR 4. 0. 3 provides a t ime limit for, and al l owances for the per formance o f,

Surveillances that become applicabl e as a consequence o f MODE change s impos ed 0by Required Ac t ions.

repeatedly Fai lure to comp ly wi th spec i f i ed frequenc ies for Surve i l l ances is expec ed to be an in frequent oc currenc e.

Use o f the de l ay per iod es tabl ished by 4. 0. 3 is a fl exibi l i ty which is not intended to be used a3 an epe:atienal coavenience to extend Surve i l lance interva l s.

Whi l e up to 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the limit of the speci fied Frequency is provi ded to perform the mis s ed Surve i l l anc e, it is expected tha t the mis sed Surveil l ance wi l l be performed a t the f irs t reasonable opportuni ty.

The determinat ion of the first reas onable opportuni ty should include cons idera t i on o f the impact on pl ant risk

( from delaying the Survei l l ance as we l l as any plant conf iguration change s required or shu t t ing the pl ant down to perform the Surveillance )

and impact on any analys i s as sump t i ons,

in addi t ion t o uni t condi tions,

planning,

ava i l abil i ty o f personnel,

and the t ime required to per f orm the Survei llance.

Thi s r i sk impac t s hou l d be managed through the program in place to implement 1 0 CFR5 0. 6 5 ( a ) ( 4 ) and i t s imp lementation guidance,

NRC Regula t ory Guide 1. 1 8 2,

' As se s s ing and Managing Ri sk Before Maintenance Ac t ivi t i e s at Nuc l ear Power P l ants. '

Thi s Regul a t ory Gui de addre sses cons i deration o f temporary and aggrega te r i s k impa c t s,

de t erminat ion of risk management ac ti on thre sholds,

and risk management action up to and including pl ant shutdown.

The mis sed Surve i l lance shoul d be treated as an emergen t condition as di s cussed in the Regul atory Guide. The risk evaluation may use quant i tative,

qual itat ive,

or bl ended methods.

The degree o f depth and r igor of the evaluat ion shoul d be c ommensurate with the importance of the component.

Mi s s ed Surve i l l anc es for important components should be analyzed quant i tatively.

If the resu l t s of the r i sk evaluation determine the risk increase is s i gnifi cant,

thi s eva luation should be us ed to de t ermine the s afes t cour s e o f action.

All missed Surve i l l ances wi l l be pla ced in the l icens ee ' s Corrective Ac ti on Program.

I f a Surve i l lanc e is not compl eted wi thin the al lowed de l ay period, then the equipment is c onsidered inoperable,

or the variabl e is cons i dered ou ts i de the speci fied limi ts, and the Comple t i on Times o f the Requi red Ac t i ons for the app l i cabl e LCD begin immediately upon expira t ion of the de lay period.

If a Surve i l l ance i s fa i l ed wi thin the del ay peri od,

then the equipment is inoperabl e,

or the vari abl e i s outs i de the spec i f i ed l imi t s,

and the Completions Time s o f the Required Act i ons for the app l i cable LCO begins immediately upon the fai lure of the Su rveillance.

Comp l e t i on o f the Survei ll ance within the de lay per iod a l l owed by thi s Spec i f i c a t i on, or wi thin the Compl e t i on Time of the Actions,

res tores c omp l i anc e wi th SR 4. 0. 1.

SALEM -

UNIT 2 B 3 / 4 0 - 7 Amendment No. 237

Insert 4 SR 4.0.3 is only applicable if there is a reasonable expectatio n the associated equ ipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance wil l be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, o r a portion thereof, has ever been perfo rmed, and any other indications, tests, or activities that might support the expectation that the S u rveillance will be met when performed. An example of the use of S R 4.0.3 would be a relay contact that was not tested as req uired in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically con nected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated eq uipment from the performance of similar eq uipment. The rigor of determining whether there is a reasonable expectation a Surveillance wil l be met when performed should i ncrease based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and eq uipment performance may be sufficient to support a reasonable expectation that the Surveillance wil l be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high deg ree of confidence that the eq u ipment is OPERABLE. The evaluation should be documented in sufficient detai l to allow a knowledgeable individual to understand the basis for the determination.

LR-N 1 8-0059 Proposed Technical Specifications Bases Changes (Mark-Up)

For Hope Creek

LR-N 18-0059 LAR H18-03 PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UP)

FOR INFORMATION ONLY The following Technical Specification Bases for Renewed Facility Operating License NPF-57 are affected by this change request:

Technical Specification Bases Page B 3/4 0-2 B 3/4 0-3 B 3/4 0-3b B 3/4 0-4 B 3/4 0-8 B 3/4 0-9

3 / 4. 0 AP PLICAB I L I TY BASES ( Con ' t l t ime l im i t s o f the ACT I ON requi rements would app l y from the point i n t ime that the new spe c i f i c a t i on become s app l i cabl e if the requi rements o f the Limi t ing Condi t i on for Ope ration are not me t.

Spe ci f i c a t i on 3. 0. 2 e s t abl i shes that noncompl iance with a speci f i ca t i on exi s t s when the requ i r eme n t s o f the Limi t ing Condi t i on for Ope r a t i on are not met and the a s sociated ACT I ON requ i rements have not been implemented wi thin the spe c i fied t ime interva l.

The purpo s e of this s pe c i f i c a t i on i s t o c l a r i fy that

( 1 )

imp l ement a t ion o f the ACT I ON requi reme n t s within the spe c i fied t ime int erval con s t i t u t e s comp l i ance with a spe c i f i ca t ion and

( 2 ) comp l e t ion o f the remedi a l measures o f the ACT I ON requi rement s i s not requi red when compl iance with a Limi t ing Condi t ion of Oper a t i on is r e s tored within the t ime interval spe c i fied in the a s s o c i a t e d ACTI ON requ i r ement s.

Spe c i f i c a t i on 3. 0. 3 e s t a b l i shes the shutdown ACT I ON requi reme n t s that mus t be implemented when a Limi t i ng Condi t i on for Ope r a t i o n is not me t and the condi t i on is not speci f i ca l l y addre s s ed by the a s s o c i a t ed ACT I ON requirement s. The purpose o f t h i s spe c i f i ca t i on i s t o de l in e a t e the t ime l imi t s for p l acing the uni t in a s a fe shutdown CON D I T I ON when pl ant ope r a t ion cannot be ma inta ined within the l imi t s for safe ope ra t i on de fined by the Limi t ing Condi t i ons for Ope ration and i t s ACT I ON requ i r ement s.

I t i s not int ended to be used as an operational convenience which permi t s

( routine )

vo lunt a r y remo v a l o f redundant s y s t ems o r component s from s ervice in l i e u o f other a l t e rnatives that would not result i n redundant s ys t ems or components being i nope rabl e.

One hour i s a l l owed t o prepare for an orde r l y shutdown before ini t i a t ing a change in pl ant ope r a t i on.

Thi s t ime permit s the operator to coordinate the reduct i on in e l e c t r i c a l gene r a t i on with the l oad dispatcher to ensure the s t abi l i t y and ava i l ab i l i t y o f the e l e c t r i c a l grid.

The t ime l imi t s spe c i fied t o reaefi wer CON D I T I ONS o f operat ion permi t the shutdown to proceed in a cont r o l l ed an e r l y manner t h a t i s we l l within the spe c i fied maximum cool down rate and wi thin cool down capabi l i t i e s of the faci l i t y a s s uming onl y the minimum required equip i s OPERABLE.

Thi s reduces thermal s t re s s e s on component s o f the primary coola stem potent i a l for a p l ant up s e t that could cha l l enge s a fe t y s ys t ems un condi t i ons f o r whi c h thi s spe c i f i c a t i on appl i e s.

I f remedi a l mea sures permi t t ing l imited cont i nued ope r a t i on o f the faci l i t y under the provi s i ons o f the ACT I ON requi rements a r e comp l e t e d,

the s hutdown may be t e rmina t e d.

The t ime l imi t s o f the ACT I ON requi remen t s are appl i cable from the point in t ime there was a fa i lure t o meet a Limi t ing Condi t i on for Opera t i on.

There fore,

the shutdown may be t e rmina ted if the ACT I ON requirement s have been me t or the t ime l imi t s o f the ACT I ON requi rement s have not exp i red, thus providin a l l owance for t h e comp l e t ion o f the requ i red actions *

, the LCO is no longer applicable, T h e t ime l imit s o f Spe c i f i c a t i on 3. 0. 3 a l l ow 3 7 h o u r s for the pl ant t o be i n COLD SHUT DOWN when a shutdown i s required during POWER oper a t i on.

I f the pl ant is in a l ower CON D I T I ON o f opera t i on when a s hut down i s required, the t ime l imi t for reaehiaq the next l ower CON D I T I ON of ope r a t i on appl i e s.

'tientering I HOPE CREEK B 3 / 4 0 - 2

we o g - 1 2 3

( PSEG I s s ue d )

3 /4. 0 APPLICAB ILITY BASES

( Con

t )

llcrev:e:r:,,i,:f a is :l'eaeeea l e s s

allowed, the..

COLD SHUTDOWN,

or o than OPERATIONAL COND ITION,

s not educ.ed.

For example,

i f ARTUP is in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ,

the t ime a l l to HOT SHUTDOWN is the next because the tot.;.l time to HOT SHUTDOWN is not reduced from the all limit of 1 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

There fore,

if remedial measure s are comp l e ted that pe rmi t a re turn to POWER ope ration,

a pena l ty is not incurred by having to..,

¥e&ef.l a lower COND ITION of operat ion in l e ss than the total t ime al lowed.

The same principle app l i e s with regard to the a l lowabl e outage t ime l imi ts o f the ACTION requirement s, i f comp l i ance wi th the ACTION requirements for one spe c i f ication resul t s in entry into an OPERATIONAL COND I T I ON or condi t ion o f opera tion for another spe c i f icat ion i n whi ch t h e requi rements o f t h e Limi ting Condi t i on for Operat ion are not me t.

I f the new speci f i cation become s appl i cable in l e s s t ime than spec i f ied,

the di f f erence may be added t o the a l lowabl e outage time l imi t s of the s.econd spe c i f i c a t i on.

However, the a l l owabl e outage t ime l imi t s of ACTION requirements for a higher COND I T I ON of ope r a t i on may not be used to ext end the a l l owable outage t ime that i s app l i cabl e when a Limi ting Cond i t i on f or Operat ion i s no t met in a l ower CONDITION of ope ration.

The shutdown requirements o f $pe c i f icat ion 3. 0. 3 do not app ly in COND ITIONS 4 and s, because the ACTION requi rements o f individual speci f i ca t ions def ine the remedial mea sure s to be ta ken.

Spec i fication 3. 0. 4 LCO 3. 0. 4 e s tabl i shes l imi tations on changes in OPERATIONAL COND ITIONS o r other speci f ied condi tions in the App l i cabi l i ty when an LCO is not me t.

It a l lows p lacing the uni t in an OPERATI ONAL COND ITION or other spe c i f i ed cond i t i on s t a te d in that App l icabi l i ty

( e. g.,

the App l i c ab i li ty de s i red to be ent e r ed )

when uni t condi t i on s are such that the requirements o f the LC 0

woul d not be me t, i n accordance wi th

LCO 3

.. 0. 4. a,

LCO 3. 0. 4. b, or LCO 3. 0. 4. c.

1. 11

. t

.. t either ACTIONS

.. o owmg en ry 1n o LCO 3. 0. 4. a ali s entry o an OPERATIONAL COND IT.ION or other spe c if ied condi t ion in the pli ility with the LCO not me t when the a s s o ciated 1\\.CTIONS to be en.te d

the OPERATIONAL CONDITION or o ther specif ied c the Appl i c ab i l i ty for an unlimi ted pe riod o f time.

Comp l i ance wi t Aeti.one that. permi t cont inued opera tion o f the uni t for an unlimit ed period of t ime in an OPERJ\\.TIONAL CONDITION or other spe c i f ied condi t ion provides an acceptable l eve l o f s a f e ty £or cont inued operation.

Thi s is wi thout regard to the s ta tus o f the uni t be f ore o r af ter the OPERATIONAL COND ITION change.

There f ore,

in such case s,

entry into an OPERATIONAL COND I T I ON o r o ther spe c i f ied condition in the App l i cabil i ty may be as s e s sment addre s s ing inoperab l e sys tems and components resul t s,

determina tion of the acceptabi l i ty of enteri COND ITION or other spe c i f ied cond i t ion in the of risk management a c t i ons,

if appropriate.

HOPE CREEK B 3 / 4 0 - 3 Amendment No.

T&&

( PSEG I s sued )

Insert 1 :

F o r e x amp l e, L C O 3. 0. 4. a ma y b e u s e d wh en the Requ i r e d Act i on t o b e ent e r e d s t a t e s t h a t an inop e r ab l e i n s t rumen t channe l mu s t b e p l a c e d i n t h e t r i p c o ndi t i o n w i t h i n t h e C omp l e t i on T ime.

T r an s i t i on i n t o a MODE o r ot her s p e c i f i e d condi t i on i n the App l i c ab i l i t y may b e made i n a c c o r dance w i t h LCO 3. 0. 4 and the chann e l is sub s e quent l y p l a c e d i n the t r ipp e d co ndi t i o n w i t h i n t h e C omp l e t i on T ime,

whi ch b e g i n s whe n the App l i cab i l i t y i s e n t e r e d.

I f t h e i n s t rumen t chann e l canno t b e p l a c e d i n t he t r ipp e d condi t i on and t h e s ub s e quent de faul t ACT I ON

( " Re qui r e d Act i on and a s s o c i a t e d Comp l e t i on T ime n o t me t " )

a l l ow s the OPERAB LE t r a i n to be p l a c e d in oper a t i on,

u s e of LCO 3. 0. 4. a i s a c c e p t ab l e because the s ub s e qu e n t ACT I ON S t o be ent e r e d f o l l ow i n g e n t r y i n t o th e MODE i n c l ude ACT I ON S

( p l a c e t he OPERABLE t r a i n i n operat i on )

t h a t p e rmi t s a f e p l ant op e r a t i o n f o r an unl imi t e d p e r i o d o f t ime i n t he MODE o r other s p e c i f i e d condi t i on to b e ent e r e d.

3/4.0 APPLICABILITY RCS Specific Activity BASES (Can't)

The risk assessments performed to justify the use of LCO 3.0.4.b usu lly only consider systems and components.

For this reason, LCO 3.0.4.c is t

'cally applied to Specifications that describe values and parameters (e.g.,

Containment Air Temperature, Containment Pressure, Moderator Temperature Coeffisient),

and may be applied to other Specifications based on NRC plant specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated OPERATIONAL CONDITION or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of LCO 3.0.4 shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that result from any unit shutdown.

In this

context, a unit shutdown is defined as a change in OPERATIONAL CONDITION or other specified condition in the Applicability associated with transitioning from OPERATIONAL CONDITION 1 to OPERATIONAL CONDITION 2, OPERATIONAL CONDITION 2 to OPERATIONAL CONDITION 3, OPERATIONAL CONDITION 3 to OPERATIONAL CONDITION 4,

and OPERATIONAL CONDITION 4 to OPERATIONAL CONDITION 5.

Upon entry into an OPERATIONAL CONDITION or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is

resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits),

as permitted by SR 4.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 4.0.1 or SR 4.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

HOPE CREEK B 3/4 0-3b Amendment No.

Ã (PSEG Issued)

3 / 4. 0 AP P L I CAB I L I T Y BASE S ( Can ' t )

Spe ci f i c a t i on 3. 0. 5 e s tabl i sh e s the a l l owances for r e s t oring equipment t o s e rvice under admi n i s t r a t ive cont rol s when i t has been removed from service or decl ared inope rable t o comp l y with ACT I ONS.

The sole purpos e of thi s Spe c i ficat ion is t o provide an exception t o LCO 3. 0. 2 ( e. g.,

t o not comp l y with t h e appl i cabl e Requ i r e d Act i ons ( s ) )

t o a l l ow t h e pe r fo rmance o f t e s t ing requi red to r e s t o r e and demons t ra t e :

a.

The O PERAB I L I T Y o f the equipment being ret urned t o s e rvice ;

or b.

The O PERAB I L I TY o f the other equipment.

The admini s t rative cont r o l s ensure the t ime the equipment i s ret urned to service in conflict with the requi rements o f the ACT I ONS i s l imi t e d to the t ime absolute l y nece s s a ry to perform the t e s ting requi red t o r e s t ore and demonstrate the OPERAB I L I T Y of the equipment.

Thi s Speci f i ca t i on doe s not provide t ime t o perform a n y other prevent ative or corrective ma int enance.

An sxampls of dsmons trat ing ths OFE@ A B I L ITY of ths squipmsnt bsing rsturned to servics is rsopsning a containmsnt isolat ion valvs that has bssn closed to comply 'oJith @ equi rsd A ctions and must bs rsopsned to psrform ths tss ting Insert 2 rsquirsd to restors and demonstrats Qpg@.n B ILITY

)

n example of demons t r a t ing the O PERAB I L ITY of other equipmen t a king an inope rab l e channe l or t r ip s ys t em out of the t ripped condi t i o t o prevent the t rip function from occurring during the performance of t e s t ing required to restore O PERAB I L I T Y of another channe l in the other trip s ys t em¢ A

similar sxampls of dsmonstrating ths OFE@ ABILITY of othsr squipmsnt i s t a king an inopsrabl s channsl or trip s ystsm out of ths trippsd condi tion t o permit the l ogic to funct ion and indicate the appropriate response during e per formance of t e s t ing requi red to restore and demons t r a t e the OPERAB I L I TY o anothe r jlnsert 3 /

channel in the s ame t rip s y s t em.

LCO 3. 0. 5 i s appl i cable t o a l l Techni c a l Spe c i f i ca t ions ;

howeve r, the intent o f LCO 3. 0. 5 is not t o s upe r s ede more speci f i c guidance cont ained wi thin any indi v i dual speci f i c a t i on.

LCO 3. 0. 8 e s t ab l i shes condi t i ons under which s y s t ems are cons idered to rema i n capab l e o f performing the i r intended s a fe t y funct i on when a s s o c i a t e d snubbers are not capabl e of providing t h e i r a s s ociated s upport funct i on ( s ).

Thi s LCO s t a t e s that the s upported s ys t em is not cons i de red t o be inope r ab l e s o l e l y due to o n e or mo re s nubb e r s n o t capab l e o f per forming the i r a s s o c i a t e d s uppo r t funct ion ( s ).

This i s approp r i a t e b e c a u s e a l imi t e d l ength o f t ime i s a l l owed f o r ma intenance,

t e s t i ng, or repai r o f one or more s nubbe r s not capabl e of pe r f o rming the i r a s s o c i a t e d support function ( s ) and approp r i a t e compensatory mea s ures are s p ec i f i ed i n t h e s nubber requi rement s, w h i c h a r e l oc a t e d outs ide o f the Techn i c a l Spe c i f i ca t i ons

( T S ) unde r l i ce n s e e cont ro l.

The snubber requirements do not meet the c r i t e r i a in 1 0 C FR 5 0. 3 6 ( d ) ( 2 ) ( i i ),

and, as s uch,

a r e approp r i a t e for cont rol by the l i censee.

HOPE CREEK B 3 / 4 0 - 4 i MC Q 9 12 3

( PS E G I s s ued )

Insert 2:

LCO 3. 0. 5 shou l d not b e u s e d i n l i eu o f o t h e r p r ac t i c ab l e a l t e rn a t i ve s that c omp l y w i th Requ i r e d Act i on s and that do n o t r e qu i r e changing the MODE or o t h e r s p e c i f i e d c ondi t i o n s in t he App l i cab i l i t y i n order t o demon s t r a t e e qu i pme n t i s OPERAB LE.

L C O 3. 0. 5 i s n ot i n t e nd e d t o b e u s e d repe a t e dl y.

An e x amp l e o f demon s t r a t i n g e quipme nt i s OPERABLE w i t h the Requi r e d Ac t i on s n o t me t i s opening a manua l va l ve that wa s c l o s e d t o comp l y w i t h R e qui r e d Act i o n s t o i s o l a t e a f l owp a t h with e x c e s s ive R e a c t o r C o o l ant S ys t em

( RC S )

P r e s s u r e I s o l a t i on Valve

( P IV )

l e a ka g e i n o r d e r t o p e r f o rm t e s t in g t o demon s t r a t e t h a t R C S P I V l e a ka g e i s n o w w i t h i n l imi t.

E x amp l e s o f demo n s t r a t ing e qu ipme nt OPERAB I L I T Y inc lude i ns t an c e s i n whi ch i t i s n e c e s s a r y t o t a ke a n inop e r ab l e channe l o r t r ip s y s t em out o f a t r ipp e d condi t i on t h a t w a s di r e c t e d b y a R e qu i r e d Ac t i on,

i f the r e i s no R e qu i r e d Ac t i on N o t e f o r thi s purp o s e.

A n e xamp l e o f v e r i fying OPERAB I L I TY o f e qu i pme n t r emoved f r om s e rv i c e i s t a k i n g a t r ip p e d chann e l out o f the t r i p p e d condi t i on t o p e rmi t th e l o g i c t o func t i on and indi c a t e the app rop r i a t e r e sp o n s e dur ing p e r f o rmanc e o f r e qu i r e d t e s t i n g o n t h e i noperab l e channe l.

E x amp l e s...

Insert 3:

The a dmi n i s t r a t i v e contr o l s in LCO 3. 0. 5 app l y i n a l l c a s e s to s y s t ems or c omp on e n t s i n Chap t e r 3 of the T e chn i c a l S p e c i f i c a t i on s,

a s l ong as the t e s t i n g cou l d not b e c onduc t e d wh i l e comp l yi n g with the R e qui r e d Ac t i on s.

T h i s i n c lude s the r e a l i gnme nt o r r e p o s i t i on i n g o f r e dundant o r a l t erna t e e qu i pme nt o r t r a i n s p r e v i ou s l y mani pu l a t e d t o c omp l y w i t h ACT I ON S,

a s we l l a s e qu i pme nt r emove d f r om s e rvi c e o r de c l a r e d i n op e r ab l e t o comp l y w i t h ACT I ON S.

3 / 4. 0 APPLICAB I L I T Y

B

A

SES(C q!n"'#t$l============================================

==**====*

Specification 4. 0. 2 e s t a b l i s he s t h e l imi t for wh i c h t h e spe c i fi ed t i me i n t e rva l for Surve i l l a nce Requ i reme n t s ma y b e e x t ended.

I t permi t s an a l lowa b l e e x t e n s i on o f t h e norma l s urve i l l a n c e i n t e rva l to fa c i l i ta t e s urve i l l a nce s c h edul i ng a nd cons i de r a t ion o f p l a n t opera t i n g con d i t io n s t h a t ma y not be s u i t a bl e for conduc t i n g t h e s ur v e i l l a n c e ;

e. g.,

t ra n s i en t cond i t i on s o r o t h e r ongo i ng su rv e i l l a nc e or ma i n t e n a n c e a c t i v i t i e s.

I t a l so provides fl e x i b i l i t y to a ccommoda t e the l ength o f a fuel c ycl e fo r surve i l l ances t h a t a re pe r formed a t e a c h r e f ue l i ng o u t a g e a n d a r e s p ec i f i e d wi t h a n 1 8 -mo n t h s urve i l l a nce i nt e r va l.

I t i s n o t i n t ended t h a t t h i s provi s i on be u s e d repe a t edl y as a GO!:'!venie!RGQ to e x t end s u rve i l l a nce i n t e rva l s be yond t h a t s p ec i f i e d for surve i l l a nc e s t h a t are not p e r formed dur i n g r e f ue l i ng o u t a g e s.

The l i mi ta t ion o f Spe c i f i ca t ion 4. 0. 2 is ba s ed on engi n e e r i ng j udgment and the recogni t ion t ha t the mos t p robabl e res ul t o f any pa r t i c u l a r su rve i l l a nce b e i ng per formed i s the v e r i f i ca t ion o f confo rma n ce wi t h t h e Surve i l l a nce Requi r emen t s.

Thi s p rov i s ion i s s u f f i c i en t to en s ure t ha t t h e re l i a bi l i t y e n s ured t h rough survei l lance a c t i v i t i e s i s not s i gn i f i ca n t l y deg raded be yond tha t ob ta i ned from t h e spe c i f i ed s urve i l l a n ce i n t e rva l.

Speci f i cat ion ibility to d e f e r dec l a ri ng a f fec t ed equipmen t i nope rabl e,

o r a n a f fected v i a b l e o ut s i de t h e speci f i ed l imi t s,

when a Surveil lance ha s no t been wi t h i n t h e speci f i ed fre quency.

A de l a y pe riod o f up t o 2 4 hou r s or up t o t h e l imi t of t h e speci f i ed frequenc y,

wh i chever i s grea t e r,

appl i es f rom t h e poi n t i n t ime t h a t i t i s d i s covered tha t t h e Surve i l l a nce has not been per forme d in a cco rda n c e wi t h TS 4. 0. 2,

a n d no t a t t h e t ime t h a t t h e spe c i f i ed f reque ncy wa s not Thi s de l a y period prov i de s a dequa t e t ime to oawplAt been mi s sed.

T h i s de l a y pe r iod pe rmi ts t he be fore comp l y i n g wi t h Requi red Ac t i on s o r othe precl ude t h e Surveillance. r---:---1.--;

tha t h a v e a

Surve i l l a n c e mea s u r e s t ha t mi g h t T h e ba s i s for t h i s de l a y pe r iod i ncl ude s con s l e ra t l on o f un i t condi t io n s,

adequa t e p l a nn i ng,

a v a i l a b i l i t y o f pe r son n e l,

t h e t ime req u i r ed t o pe r fo rm t h e Surve i l l a nce,

the s a f e t y s i gn i f i ca nce o f t h e de l a y i n comp l e t i n g t h e requ i red S u r ve i l l a nc e,

a nd t h e recogn i t ion tha t t h e mos t p roba b l e r e s u l t o f a n y pa r t i cu l a r Surve i l l a n c e be i ng pe r fo rmed i s t h e v e r i f i ca t ion o f con fo rma nce wi t h t h e requi remen t s.

When a S u rve i l l a nc e wi t h a frequency ba sed n o t on t ime i n t e rva l s, but upon spec i f i ed u n i t cond i t ions,

ope ra t i ng s i t ua t ions,

or requi reme n t s o f regul a t i ons

( e. g.,

prior to en t e r i n g Mode 1

a ft er ea ch f u e l loading,

o r i n a ccorda nce wi t h l OC FR S O Appendi x J,

a s modi f i e d b y a pp rov e d e x empt i on s,

e t c. )

i s d i s cove r ed no t t o h a v e been performed when s p ec i f i e d,

S R 4. 0. 3 a l lows t h e fu l l de l a y pe r i od o f up to t h e s pe c i f i e d Frequency t o pe r fo rm t h e Surve i l l a nce.

H o we ve r,

s i nc e there i s n o t a t i me i n t e r v a l s p ec i f i e d,

t h e mi s s e d S u r v e i l l a n c e s hou l d be p e r fo rme d a t t h e f i r s t r ea son a b l e oppo r t un i t y.

SR 4. 0. 3 a l so p rov i de s a t ime l imi t for, and a l l owa n c e s for t h e p e r forma nce of, Surve i l l a nc e s t ha t become a ppl i ca bl e as a co n s equ en ce o f MODE cha n g e s impo s ed by Requi red Ac t i ons.

HOPE CREEK B 3 / 4 0 - 8

!Insert 4 I 4 we 0 9 1 2 3

( PSEG I s sued )

Insert 4:

S R 4. 0. 3 i s o n l y app l i c ab l e i f the r e i s a r e a s onab l e e xp e c t a t i on t h e a s s o c i a t e d e qu ipme n t i s OPERABL E o r t h a t var i ab l e s a r e w i t h i n l imi t s,

a n d i t i s e xp e c t e d that t h e Surve i l l ance wi l l be me t whe n p e r f orme d.

Many f a c t o r s s h o u l d b e c on s i de r e d,

s u c h a s t h e p e r i od o f t ime s i n ce t h e Surve i l l an c e w a s l a s t p e r f o rme d,

o r whe t h e r the Surve i l l anc e,

o r a p o r t i o n t h e r e o f,

h a s eve r b e e n p e r f o rme d,

and any othe r i n di c a t i on s,

t e s t s,

or a c t i vi t i e s t h a t mi ght s upp o r t the e xp e c t a t i on that the Surve i l l an c e wi l l b e me t whe n p e r f o rme d.

An e x amp l e o f t h e u s e o f S R 4. 0. 3 would b e a r e l a y contact that wa s n o t t e s t e d a s r e qu i r e d i n a c c o rdance w i t h a part i cu l a r S R, but p revious s u c c e s s fu l p e r f o rmanc e s o f the S R inc lude d the r e l ay contact ;

the adj acen t,

phys i c a l l y conn e c t e d r e l a y cont a c t s we r e t e s t e d dur i n g t h e S R p e r f o rmanc e ;

t h e s ub j e c t r e l a y cont a c t h a s b e e n t e s t e d b y ano t h e r S R ;

or h i s t or i c a l op e ra t i on o f t h e subj e c t r e l a y cont a c t h a s b e e n s u cc e s s ful.

I t i s not s u f f i c i e n t t o i n f e r t h e behavi o r o f t h e a s s oc i a t e d e qu i pment f r om t h e p e r forman c e o f s imi l a r e quipme nt.

The r i go r o f de t e rmi n i n g whe t h e r t h e r e i s a r e a s onab l e e xp e c t at i on a

Surve i l l an c e wi l l b e me t whe n p e r f orme d should i n c r e a s e b a s e d on the l e ngth of t ime s i n c e the l a s t p e r f o rmance o f the Surve i l l anc e.

I f the Surve i l l an c e h a s b e e n p e r f o rme d r e c e nt l y,

a r e v i e w o f the Surve i l l an c e hi s t o r y and e qu i pme nt p e r f o rmance ma y b e s u f f i c i ent to s upp o r t a r e a s onab l e e xp e c t a t i o n t h a t t h e Surve i l l an c e wi l l b e me t whe n p e r f o rmed.

F o r Surve i l l an c e s t h a t have n o t b e e n p e r f o rme d f o r a l on g p e r i od o r that have never been p e r f o rme d,

a r i gorous evaluat i on b a s e d on ob j e c t i ve evidence should p r ov i d e a h i gh de g r e e o f con f i de n c e that the e qu ipme n t i s O PERABLE.

T h e evalua t i o n s h ou l d b e do cume nt e d i n s u f f i c i ent de t a i l t o a l l ow a know l e dg e ab l e indi v i du a l t o unde r s t and t h e b a s i s f o r t h e de t e rmi nat i on.

3 / 4. 0 APPLICABILITY repeatedly BASES

( Can ' t )

Fai lure t o comply with spe c i f ied frequenc ies for Surve i l l ance s i s e be an infrequent oc currence.

Use of the de l ay period e s t ab l i shed by i s a f l exibi l i ty which i s not intended t o be used as an operational eorenienee to extend Surve i l l ance interva l s.

Whi le up to 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the l imit of the spe c i f ied Frequency is provided to perform the mi s sed Surve i l l ance,

i t is expected that the mi s s ed Surve i l l ance wi l l be performed at the f i r s t reasonable opportunity.

The determination of the f i r s t reasonab l e opportunity should inc lude c ons ideration of the impact o n plant r i s k ( f rom de l aying the Surve i l lance a s wel l as any plant conf igurat i on changes requi red or shutting the p l ant down t o perform the Surve i l l ance )

and impact on any analys i s as sumptions,

in addition to unit conditions,

pl anning,

availab i l i ty o f personnel,

and the t ime requi red to perform the Surve i l l ance.

Thi s r i s k impact should be managed through the program in place t o implement 1 0 CFR5 0. 6 5 ( a ) ( 4 )

and i t s implementation guidance,

NRC Regul atory Guide 1. 1 8 2,

' As s e s s ing and Managing Risk Be fore Maintenance Act ivi t i e s at Nuc lear Power P l ant s. '

Thi s Regul atory Guide addre s s e s cons ideration o f temporary and aggregate risk impact s,

determinat ion of r i s k management a c t i on thre sholds,

and r i s k management act ion up to and inc luding p l ant shutdown.

The mi s sed Surve i l l ance should be treated as an emergent condition as di s cussed in the Regulatory Guide.

The risk evaluat ion may use quant itat ive,

qua l i t a t ive,

o r b l ended methods.

The degree of depth and rigor o f the evaluation should b e commensurate with t h e importance o f the component.

Mi s s ed Surve i l l ance s for important components should be analyzed quant itatively.

If the resul t s of the r i s k evaluation determine the risk increas e is s igni f i cant,

thi s evaluation should be used to determine the safest course o f action.

Al l mi s s ed Surve i l l ance s wi l l be p l aced in the l i censee ' s Corrective Act i on Program.

I f a Surve i l l ance i s not completed within the a l l owed de l ay period,

then the equipment is cons idered inoperable,

or the variable is cons idered out s ide the spe c i f ied l imit s, and the Completion Times of the Required Actions for the app l i cable LCO begin immediately upon expirat ion of the de l ay period.

If a Surve i l l ance i s f a i l ed within the de l ay period,

then the equipment i s inoperable,

o r the variable is outs ide the spe c i f ied l imits,

and the Comp l e t i ons Time s of the Required Act i ons for the app l i c ab l e LCO begins immediately upon the fai lure o f the Surve i l l ance.

Comp l e t i on o f the Surve i l lance within the delay period a l l owed by thi s Spe c i f i cation,

or within the Complet ion Time o f the Act i ons,

restores comp l i ance with SR 4. 0. 1.

Specif i cation 4. 0. 4 SR 4. 0. 4 e s t ab l i she s the requi rement that all app l i cab l e S R s mus t be met before entry into a n OPERATIONAL CONDITION o r other spe c i f ied condit ion in the App l i c ab i l i ty.

Thi s Spe c i f i cation ensure s that sys tem and c omponent OPERAB I L I TY requi rements and variable l imi ts are met be f ore entry into OPERATIONAL CONDITIONS o r other spe c i f ied conditions in the App l i cabi l i ty for whi ch the s e sys tems and components ensure safe operation of the uni t.

The provi s i ons o f thi s Spe c i f i cation should not be interpreted as endors ing the f a i lure to exerc i s e the good practice of restoring sys tems or component s to OPERABLE s tatus before entering an associated OPERATIONAL CONDITION or other spec i f ied condi tion in the App l i cabi l i ty.

HOPE CREEK B 3 / 4 0 - 9 Amendment No.

( PSEG I s sued )

v t e Letter Sequence Request
EPID:L-2018-LLA-0185, TSTF-529 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2018-07-20 [Table View]

LR-N18-0059, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

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LR-N18-0059, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

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Subject:

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4.0 ENVIRONMENTAL CONSIDERATION

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