CNRO-2019-00003, Application to Revise Technical Specifications to Adopt TSTF-529 11 Clarify Use and Application Rules, 11 Revision 4
ML19032A256 | |
Person / Time | |
---|---|
Site: | Palisades, Indian Point, Grand Gulf, Arkansas Nuclear, River Bend, Waterford ![]() |
Issue date: | 01/31/2019 |
From: | Halter M Entergy Nuclear Operations, Entergy Operations |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
CNRO-2019-00003, TSTF-529, Rev 4 | |
Download: ML19032A256 (201) | |
Text
Entergy Operations, Inc. and Entergy Nuclear Operations, Inc.
-===* Enterµv 1340 Echelon Parkway Jackson, MS 39213 bJ@ Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.90 CNR0-2019-00003 January 31, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 11
Subject:
Application to Revise Technical Specifications to Adopt TSTF-529 Clarify Use 11 and Application Rules, Revision 4 Arkansas Nuclear One, Units 1 and 2 N RC Docket Nos. 50-313 and 50-368 Renewed Facility Operating License Nos. DPR-51 and NPF-6 Grand Gulf Nuclear Station, Unit 1 NRG Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Indian Point Nuclear Generating Units 2 and 3 NRG Docket Nos. 50-247 and 50-286 Renewed Facility Operating License Nos. DPR-26 and DPR-64 Palisades Nuclear Plant NRG Docket No. 50-255 Renewed Facility Operating License No. DPR-20 River Bend Station, Unit 1 N RC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Waterford Steam Electric Station, Unit 3 NRG Docket No. 50-382 Renewed Facility Operating License No. NPF-38 In accordance with Title 1O of the Code of Federal Regulations (CFR) Part 50, Section 50.90, 11 Application for amendment of license, construction permit, or early site permit, Entergy 11 Operations, Inc. and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy) are submitting a request for an amendment to Renewed Facility Operating License, Appendix A, Technical Specifications (TS) for Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear 11 11
CNR0-2019-00003 Page 2 of 4 Station, Unit 1; Indian Point Nuclear Generating Units 2 and 3; Palisades Nuclear Plant; River Bend Station, Unit 1; and Waterford Steam Electric Station, Unit 3.
The proposed changes revise TS Section 1.3, "Completion Times," and TS Section 3.0, "LCO Applicability" to clarify the use and application of the TS usage rules. These proposed changes are consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4.
The Enclosure to this letter provides a description and assessment of the proposed changes.
Attachments 1.a through 1.f provide the existing TS pages marked-up to show the proposed changes. Attachments 2.a through 2.f provide revised (clean) TS pages. Attachments 3.a through 3.f provide, for information only, marked up versions of existing TS Bases pages to show the proposed changes.
This letter contains no new regulatory commitments.
Entergy requests approval of the proposed license amendment by February 1, 2020. The proposed changes would be implemented within 90 days of issuance of the amendment.
Should you have any questions or require additional information, please contact Stephenie Pyle at (601) 368-5516.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.
I declare under penalty of perjury, the foregoing is true and correct. Executed on 31st day of January 2019.
Respectfully, 4
Jna~J{l?d~t_
Mandy K. Halter MKH/jls
CNR0-2019-00003 Page 3 of 4
Enclosure:
Description and Assessment of the Proposed Changes Attachments:
1.a. Markup of Technical Specification (TS) Pages - Arkansas Nuclear One, Units 1 and 2 1.b. Markup of Technical Specification (TS) Pages - Grand Gulf Nuclear Station, Unit 1 1.c. Markup of Technical Specification (TS) Pages - Indian Point Nuclear Generating Units 2 and 3 1.d. Markup of Technical Specification (TS) Pages - Palisades Nuclear Plant 1.e. Markup of Technical Specification (TS) Pages - River Bend Station, Unit 1 1.f. Markup of Technical Specification (TS) Pages - Waterford Steam Electric Station, Unit 3 2.a. Clean Technical Specification (TS) Pages -Arkansas Nuclear One, Units 1 and 2 2.b. Clean Technical Specification (TS) Pages - Grand Gulf Nuclear Station, Unit 1 2.c. Clean Technical Specification (TS)* Pages - Indian Point Nuclear Generating Units 2 and 3 2.d. Clean Technical Specification (TS) Pages - Palisades Nuclear Plant 2.e. Clean Technical Specification (TS) Pages - River Bend Station, Unit 1 2.f. Clean Technical Specification (TS) Pages - Waterford Steam Electric Station, Unit 3 3.a. Markup of Technical Specification (TS) Bases Pages - For Information Only-Arkansas Nuclear One, Units 1 and 2 3.b. Markup of Technical Specification (TS) Bases Pages - For Information Only-Grand Gulf Nuclear Station, Unit 1 3.c. Markup of Technical Specification (TS) Bases Pages - For Information Only-Indian Point Nuclear Generating Units 2 and 3 3.d. Markup of Technical Specification (TS) Bases Pages - For Information Only-Palisades Nuclear Plant 3.e. Markup of Technical Specification (TS) Bases Pages - For Information Only-River Bend Station, Unit 1 3.f. Markup of Technical Specification (TS) Bases Pages - For Information Only-Waterford Steam Electric Station, Unit 3
CNR0-2019-00003 Page 4 of 4 cc: NRC Region I - Regional Administrator NRC Region Ill - Regional Administrator NRC Region IV - Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One, Units 1 and 2 NRC Senior Resident Inspector - Grand Gulf Nuclear Station, Unit 1 NRC Senior Resident Inspector - Indian Point Nuclear Generating Units 2 and 3 NRC Senior Resident Inspector - Palisades Nuclear Plant NRC Senior Resident Inspector - River Bend Station, Unit 1 NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRC Project Manager - Entergy Fleet Arkansas Department of Health, Radiation Control Section State Health Officer, Mississippi Department of Health President and CEO, NYSERDA New York State Public Service Commission Michigan Department of Environmental Quality Louisiana of Department of Environmental Quality
bee w/o attachments:
L. Coyle J. Ventosa Site Vice President - Arkansas Nuclear One, Units 1 and 2 Site Vice President - Grand Gulf Nuclear Station, Unit 1 Site Vice President - Indian Point Nuclear Generating Units 2 and 3 Site Vice President - Palisades Nuclear Plant Site Vice President - River Bend Station, Unit 1 Site Vice President -Waterford Steam Electric Station, Unit 3 K. Jury R. Gaston M. Halter J. Giddens S. Pyle bee w/ attachments:
NRC Project Manager - Arkansas Nuclear One, Units 1 and 2 NRC Project Manager - Grand Gulf Nuclear Station, Unit 1 NRC Project Manager - Indian Point Nuclear Generating Units 2 and 3 NRC Project Manager- Palisades Nuclear Plant NRC Project Manager - River Bend Station, Unit 1 NRC Project Manager - Waterford Steam Electric Station, Unit 3 Regulatory Assurance Manager -Arkansas Nuclear One, Units 1 and 2 Regulatory Assurance Manager - Grand Gulf Nuclear Station, Unit 1 Regulatory Assurance Manager - Indian Point Nuclear Generating Units 2 and 3 Regulatory Assurance Manager - Palisades Nuclear Plant Regulatory Assurance Manager - River Bend Station, Unit 1 Regulatory Assurance Manager - Waterford Steam Electric Station, Unit 3 George Vickery - Corporate Operations David Bice - ANO Licensing Ryan Sexton - Grand Gulf Licensing Mahvash Mirzai - IPEC Licensing Jim Miksa - Palisades Licensing Bridget Johns - River Bend Licensing Maria Zamber - Waterford Licensing John Schrage - Corporate Regulatory Assurance
ENCLOSURE CNR0-2019-00003 Description and Assessment of the Proposed Changes Application to Revise Technical Specifications to Adopt 11 TSTF-529 "Clarify Use and Application Rules, Revision 4 Arkansas Nuclear One, Units 1 and 2 Grand Gulf Nuclear Station, Unit 1 Indian Point Nuclear Generating Units 2 and 3 Palisades Nuclear Plant River Bend Station, Unit 1 Waterford Steam Electric Station, Unit 3 (6 Pages) 1.0 Description 2.0 Assessment 2.1 Applicability of Published Safety Evaluation 2.2 Variations 3.0 Regulatory Analysis 3.1 No Significant Hazards Determination 4.0 Environmental Consideration 5.0 References
CNR0-2019-00003 Enclosure Page 1 of 6 1.0 Description In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. and Entergy Nuclear Operations, Inc.
(collectively referred to as Entergy) are submitting a request for an amendment to the Renewed Facility Operating License (RFOL), Appendix A, 'Technical Specifications" (TS) for Arkansas Nuclear One, Units 1 and 2 (AN0-1 and AN0-2, collectively referred to as ANO); Grand Gulf Nuclear Station, Unit 1 (GGNS); Indian Point (IP)
Nuclear Generating Units 2 and 3 (IP2 and IP3, collectively referred to as IPEC);
Palisades Nuclear Plant (PNP); River Bend Station, Unit 1 (RBS); and Waterford Steam Electric Station, Unit 3.
The proposed changes revise TS Section 1.3, "Completion Times, and TS Section 11 3.0, "LCO Applicability" to clarify the use and application of the TS usage rules, as described below. These proposed changes are consistent with NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and 11 Application Rules, Revision 4:
- TS Section 1.3, is revised to clarify "discovery" and to discuss exceptions to starting the Completion Time at condition entry.
- 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) 3.0.3 (or equivalent) is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.
2.0 Assesment 2.1 Applicability of Published Safety Evaluation Entergy has reviewed the Nuclear Regulatory Commission (NRG) Safety Evaluation (SE) for TSTF-529, Revision 4 (ADAMS Accession No. ML16060A440), which was transmitted to the TSTF in a letter dated April 21, 2016 (ADAMS Accession No. ML16060A455). This included a review of the NRG SE, as well as the information provided in TSTF-529. Entergy has concluded that the justifications presented in TSTF-529 proposal and the NRG SE are applicable to ANO, GGNS, IPEC, PNP, RBS, and Waterford and justify this amendment for the incorporation of the changes to each plant's TS.
CNR0-2019-00003 Enclosure Page 2 of 6 2.2 Variations Entergy is proposing the following variations from the TS or TS Bases changes described in TSTF-529. These variations do not affect the applicability of TSTF-529 or the NRC SE to the proposed license amendment.
2.2.1 AN0-1 None 2.2.2 AN0-2
- i. AN0-2 TS Section 1.0, "Definitions" does not currently include a definition for "Completion Time." As a result, the proposed changes to the AN0-2 TS do not include the TSTF-529 revision to TS 1.3, "Completion Time." This variation is administrative, and consistent with the current AN0-2 TS, as well as the underlying basis for the current AN0-2 TS (i.e., NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors"). In addition, as discussed in TSTF-529, omission of one or more changes is an acceptable variation from the traveler.
ii. The current AN0-2 TS format, numbering, and terminology is consistent with the NUREG-0212 Standard Technical Specifications (STS). The NUREG-0212 STS numbering for survejllance requirements differs from the numbering in NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants," (i.e., the Improved STS which were used to develop TSTF-529). As a result, the TSTF-529 revision to SR 3.0.3 has been incorporated into proposed changes to AN0-2 TS 4.0.3. This variation is administrative, consistent with the current AN0-2 TS, as well as the underlying NUREG-0212 basis for the current AN0-2 TS, and does not affect the applicability of TSTF-529 to th,e AN0-2 TS.
iii. Similarly, the TSTF-529 revision to TS Bases LCO 3.0.5 and TS Bases SR 3.0.3 have been incorporated into proposed changes to AN0-2 TS Bases LCO 3.0.6 and AN0-2 TS Bases SR 4.0.3, respectively. These variations are administrative, consistent with the current AN0-2 TS, as well as the underlying NUREG-0212 basis for the current AN0-2 TS, and do not affect the applicability of TSTF-529 to the AN0-2 TS.
iv. AN0-2 TS SR 4.0.3 refers to "specified surveillance interval," which is consistent with NUREG-0212, but represents a variation from the NUREG-1432 SR 3.0.3 terminology, which refers to "specified Frequency." This variation is administrative, consistent with the current AN0-2 TS, as well as the underlying NUREG-0212 basis for the current AN0-2 TS, and does not affect the applicability of TSTF-529 to the AN0-2 TS.
CNR0-2019-00003 Enclosure Page 3 of 6 2.2.3 GGNS None 2.2.4 IPEC None 2.2.5 PNP
- i. The proposed change to PNP TS 1.3 differs from TSTF-529 TS 1.3 by using 11 11 the current PNP term plant instead of "unit" in the BACKGROUND section (one occurrence) and the DESCRIPTION section (two occurrences). This terminology reflects the licensed name for PNP, which does not specify a unit number. This variation is administrative and consistent with the current PNP TS, and does not affect the applicability of TSTF-529 to the PNP TS.
ii. The format of the proposed change to PNP TS Bases LCO 3.0.5 differs slightly from the TSTF-529 TS Bases LCO 3.0.5 in that the two numbered examples of demonstrating OPERABILITY of other equipment (i.e., on PNP TS Bases page 3.0-8) are on separate lines, as opposed to within the body of the paragraph.
This variation is administrative, consistent with the current PNP TS Bases format, and does not affect the applicability of TSTF-529 to the PNP TS.
2.2.6 RBS
- i. The proposed change to RBS TS Bases SR 3.0.3 deletes a site-specific statement that limits the use of a delay period for performance of missed SRs to those surveillances where the initial surveillances have been successfully performed. This deletion is consistent with the TSTF-529 revision to Bases SR 3.0.3 which adds additional requirements for surveillances that have not been performed for a long period of time or that have never been performed.
2.2.7 Waterford
- i. Waterford TS Section 1.0, "Definitions" does not currently include a definition for "Completion Time." As a result, the, the proposed changes to the Waterford TS do not include the TSTF-529 revision to TS 1.3, "Completion Time." This variation is administrative, and consistent with the current Waterford TS, as well as the underlying NUREG-0212 basis for the current Waterford TS. In addition, as discussed in TSTF-529, omission of one or more changes is an acceptable variation from the traveler.
ii. The current Waterford TS format, numbering, and terminology is consistent with NUREG-0212. The NUREG-0212 STS numbering for surveillance requirements differs from the numbering in NUREG-1432. As such, the TSTF-529 revision to SR 3.0.3 has been incorporated into proposed changes to Waterford TS 4.0.3. This variation is administrative, consistent with the current Waterford TS, as well as the underlying NUREG-0212 basis for the current Waterford TS, and does not affect the applicability of TSTF-529 to the Waterford TS.
CNR0-2019-00003 Enclosure Page 4 of 6 iii. Similarly, the TSTF-529 revision to TS Bases SR 3.0.3 has been incorporated into proposed changes to Waterford TS Bases SR 4.0.3. This variation is administrative, consistent with the current Waterford TS, as well as the underlying NUREG-0212 basis for the current Waterford TS, and does not affect the applicability of TSTF-529 to the Waterford TS.
iv. Waterford TS SR 4.0.3 refers to "specified surveillance interval," which is consistent with NUREG-0212, but represents a variation from the NUREG-1432 SR 3.0.3 terminology, which refers to "specified Frequency." This variation is administrative, consistent with the current Waterford TS, as well as the underlying NUREG-0212 basis for the current Waterford TS, and does not affect the applicability of TSTF-529 to the Waterford TS.
- v. The current Waterford TS 3.0.4 is based on the equivalent TS in NUREG-0212, which is different from TS 3.0.4 in NUREG-1432, Revision 3. Therefore, the proposed Waterford TS changes do not include the TSTF-529 revision to LCO 3.0.4 and Bases LCO 3.0.4. This variation is administrative, and consistent with the current Waterford TS, as well as the underlying NUREG-0212 basis for the current Waterford TS. In addition, as discussed TSTF-529, omission of one or more changes is an acceptable variation from the traveler.
3.0 Regulatory Analysis 3.1 No Significant Hazards Determination Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (collectively referred to as Entergy) request adoption of NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules, 11 Revision 4 into the Technical Specifications (TS) of Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; Indian Point Nuclear Generating Units 2 and 3; Palisades Nuclear Plant; River Bend Station, Unit 1; and Waterford Steam Electric Station, Unit 3.
11 The proposed changes revise Section 1.3, "Completion Times, and Section 3.0, "LCO Applicability" and "SR Applicability" of the TS to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3 (or equivalent). Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS.
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 3.0.3 (or equivalent) is revised to allow application of SR 3.0.3 when an SR has not been previously performed. These proposed changes are consistent with TSTF-529.
Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment, 11 as discussed below:
CNR0-2019-00003 Enclosure Page 5 of 6
- 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 Section 1.3 and 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 3.0.3 (or equivalent) 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 these changes do 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 changes to the TS usage rules do not affect the design or function of any plant systems. The proposed changes do not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.
Therefore, it is concluded that the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed changes clarify the application of Section 1.3 and LCO 3.0.4 and do not result in changes in plant operation. SR 3.0.3 (or equivalent) is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 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 the changes do not involve a significant reduction in a margin of safety.
CNR0-2019-00003 Enclosure Page 6 of 6 Based on the above, Entergy concludes that the proposed amendments do not present a 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 amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in Title 10 of the Code of Federal Regulations (CFR) Part 20 (1 O CFR 20), or would change an inspection or surveillance requirement. However, the proposed changes do 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 11 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) ADAMS Accession Nos. ML16060A455 (Letter/Public);
ML16060A440 (Final SE/Public); ML16060A441 (Package/Public).
ATTACHMENT 1.a CN R0-2019-00003 Markup of Technical Specification (TS) Pages Arkansas Nuclear One, Unit 1 NRC Docket No. 50-313 Renewed Facility Operating License No. DPR-51 Unit 1 TS Pages 1.3-1 1.3-2 1.3-3*
1.3-4*
1.3-5*
1.3-6*
1.3-7*
1.3-8*
1.3-9*
1.3-10*
3.0-1 3.0-4
- Unit 1 TS Pages 1.3-3 through 1.3-10 are included due to repagination only.
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded. the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
AN0-1 1.3-1 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the Yme e-f-discovery of the situation that required entry into the Condition. unless otherwise specified.
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
AN0-1 1.3-2 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times (continued)
DESCRIPTION (continued)
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AN0-1 1.3-3 Amendment No. ~ ,
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1 .3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.
B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated.
When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.
LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.
AN0-1 1.3-4 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for> 7 days.
EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to train OPERABLE AND inoperable. status.
10 days from discovery of failure to meet the LCO B. One 8.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to train OPERABLE AND inoperable. status.
10 days from discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X train to train OPERABLE inoperable. status.
AND OR One C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to OPERABLE train status.
AN0-1 1.3-5 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).
The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.
AN0-1 1.3-6 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1.3-4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve(s) to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE inoperable. status.
B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.
Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (plus the extension) expires while one or more valves are still inoperable, Condition B is entered.
AN0-1 1.3-7 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1.3-5 ACTIONS
NOTE-------------------------------------------
Se pa rate Condition entry is allowed for each inoperable valve.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE inoperable. status.
B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.
The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis.
When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve.
AN0-1 1.3-8 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve.
Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.
EXAMPLE 1.3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.1 Perform Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. SR 3.x.x.x.
OR A.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to
~ 50% RTP.
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated Completion Time not met.
Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance. The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval. If Required Action A.1 is followed and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2),
Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met, Condition B is entered.
If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A.
AN0-1 1.3-9 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Verify affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> subsystem subsystem isolated.
inoperable. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND A.2 Restore subsystem to OPERABLE 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> status.
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" interval begins upon performance of Required Action A.1.
If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2),
Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.
IMMEDIATE When "Immediately" is used as a Completion Time, the Required COMPLETION TIME Action should be pursued without delay and in a controlled manner.
AN0-1 1.3-10 Amendment No. ~,248,
LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
- a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
- b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
- c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 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;
- 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 appropriate-;- .(exceptions to this Specification are stated in the individual Specifications1:i- or AN0-1 3.0-1 Amendment No. ~.~.~.2-59.
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
AN0-1 3.0-4 Amendment No.~.~.~.~.
ATTACHMENT 1.a (continued)
CNR0-2019-00003 Markup of Technical Specification (TS) Pages Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 Unit 2 TS Pages 3/4 0-1 3/4 0-2
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation (LCO) and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification, except as provided in LCO 3.0.2, LCO 3.0.8, and LCO 3.0.9.
3.0.2 Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in Specification 3.0.6. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.
3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a mode in which the specification does not apply by placing it, as applicable, in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless corrective measures are completed that permit operation under the permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor is placed in a MODE in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specification.
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;
- 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 appropriate-;- {exceptions to this Specification are stated in the individual Specifications}, or
- 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.
ARKANSAS - UNIT 2 3/4 0-1 Amendment No. 4-9,4M,2-07,2-84,
~.~.
APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the Surveillance.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified interval shall be failure to meet the LCO except as provided in 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 interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
4.0.4 Entry into a MODE or other specified condition in the Applicability shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided in 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 shall not prevent entry into 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.
ARKANSAS - UNIT 2 3/4 0-2 Amendment No. 42,4-03,434,~,249.
~.
ATTACHMENT 1.b CNR0-2019-00003 Markup of Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Unit 1 TS Pages 1.0-11 3.0-2 3.0-4
Completion Times 1.3 1.0 US£ AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the -t4ffle.
--e+-discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to expiration of the specified Completion T' . An ACTIONS Condition remains in effect and the Re
- ed Actions apply until the Condition no longer
- s or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef discovery of the situation that required entry into the Condition.
Once a Condition has been entered, subsequent div' ions, subsystems, components, or variables expressed i the Condition, discovered to be inoperable or not w* hin limits, will not result in separate entry into the Con ition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failur, with Completion Times based on initial entry in the Conditio .
, unless otherwise specified (continued l.
GRAND GULF 1.0-11 Amendment No. -He-
Insert 1 (TS 1.3, Completion Times, page 1.0-11)
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After perfo mance of a risk assessment addressing (continued) inoperable s stems and c mponents, consideration of the results, det rmination o the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if ap ropriat~exceptions to this Specification re stated in the individual Specifications or
- c. When an allowance is stated in the individual value, parameter, or other Specification.
1his 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.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program CSFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
(continued)
GRAND GULF 3.0-2 Amendment No. -+/--4-& * ..J:.7.§-
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . . " basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of
-r 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 surveill e delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk sha 11 be managed.
The delay period is only applicable when there is a If the Surveillance is not performed within the delay reasonable expectation the period, the LCO must immediately be declared not met, and surveillance will be met the applicable Condition(s) must be entered.
when performed.
continued GRAND GULF 3.0-4 Amendment No.~ 3:-5-r--
ATTACHMENT 1.c CNR0-2019-00003 Markup of Technical Specification (TS) Pages Indian Point Nuclear Generating Unit 2 NRC Docket No. 50-247 Renewed Facility Operating License No. DPR-26 Unit 2 TS Pages 1.3-1 3.0-2 3.0-4
Comp1etion Times 1.3 u 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion TI me convention and lo provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail lo be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time aUowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit Is in a MODE or specified condition stated in the Applicability of the L . equired Actions must be completed prior to the expiration of the spe * ,ed Completion Time. An ACTIONS Condition remains in effect and th equired Actions apply unlit the Condition no longer exists or the unit is ot within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (mu1tiple Conditions), the Required Actions for Insert Ne each Condition must be performed within the associated Completion Tame.
When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time or discovery of the situation that required entry Jnto the Conditi
- One ition has been entered, subsequent trains, subsystems,
, unless otherwise components. or variabl~s expressed in the Condition, discovered to 'be specified inoperable or not within limits, wi11 not result in separate entry into the
---OGRCru* ion, unless specifically stated. The Required Actions of the Condition continue to each additiona1 fai1ure, with Completion Times based on initial entry into the Con * * .
However, when a subsequent train, subsystem, component. or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Ttme(s) may be extended. To apply thjs CompJetion Time extension, two criteria must first be met. The subsequent inoperabitity:
- a. Must exist concurrent with the first inoperabitity and INDIAN POINT 2 1.3 .. 1 Amendment No. %5&
Insert 1 (TS 1.3, Completion Times, page 1.3-1)
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
LCO Applicability 3.0
- b. After perfor ance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the accep ability of entering the MODE or other specified condition in the Appti bility, and establishment of risk management actions, if appropriat~exceptions to this Specification are stated in the individual Specification7'or .
- c. When an allo~~s stated In the individual value, parameter, or other Specification. l\"l LG 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.
LCO 3.0.5 Equipment removed from service or decfared inoperable to comply with
. ACTIONS may be returned to service llnder administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
u LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Technical Specification 5.5.13, **safety Function Determination Program {SFDP)." If a loss of safety function is determined .to exist by this program, the appropriate ConditiOr)S and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
- When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
\_) INDJAN POINT 2 3.0*2 Amendment No.~
SR Applicability 3.0 u
. .3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions Jn the Applicability for individuat LCOs, unless otherwise stated in the SR. Fatlure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided In SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the Jnterval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not ..
- apply.
If a Completion Time requires periodic performance on a "once per ***"
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency. then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.~~ risk evaluation shall be performed for any Surveillance delayed greater11han 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance ls no\ performed within the de1a ~ period, the LCO must immedjately be declared not met, and the appUcat: e Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
The delay period is only applicable when there is a reasonable expectation the
-, surveillance will be met when performed.
\._) JNDIAN POINT 2 3.0-4 Amendment No. 2a&
ATTACHMENT 1.c (continued)
CNR0-2019-00003 Markup of Technical Specification (TS) Pages Indian Point Nuclear Generating Unit 3 NRG Docket No. 50-286 Renewed Facility Operating License No. DPR-64 Unit 3 TS Pages 1.3-1 1.3-2 3.0-2 3.0-4
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated With an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met.
Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g .* inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a HOOE or specified condition stated in the Applicability of the LCO quired Actions must be completed prior to the expiration of he spe
- ied Completion Time.
An ACTIONS Condition remains in e ect and the Re
- ed Actions apply until the Condition no lo er exists or the unit* ot within the LCO Applicability. ......,n-s_e_rt_N_e_VJ_
Paragraph If situations are discovered that require entry into more than one........_--~--
Condition at a time within a single LCO (multiple Conditions). the Required Actions for each Condition must b~ performed within the associated Completion Time. When in multiple Conditions. separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.
- Once a Condition has been entered. subsequent trains. subsystems.
comp ents. or variables expressed in the Condition. discovered to
- be noperable or not within limits. will not result in separate e ry into the Condition. unless specifically stated. The Required ctions of the Condition continue to apply to each
, unless otherVJise specified u (continued)
INDIAN POINT 3 1.3*1 lwendrnent ~
Insert 1 (TS 1.3, Completion Times, page 1.3-1)
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
, unless otherwise specified Completion Times 1.3 1.3 Com letion Times V DESCRIPTION additional failur. with Completion Times based on initial entry (continued) into the Conditio However. when a subsegueat train. subsystem, component. or variable expressed in the Condition is discovered to be inoperable or not within limits. the Completion Time(s) may be extended. To apply this Completion Time extension. two criteria must first be met. The subsequent inoperability:
- a. Hust exist concurrent with the .fir.s:t inoperability: and
- b. Hust remain inoperable or not within limits after the first inoperability is resolved.
The tot~l Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time. as measured from the initial entry into the Condition. plus an additional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: or
- b. The stated Completion Time as measured from discovery of the V subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem. component.
or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension.does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time Ci.e ** "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.* where the Completion Time is referenced from a previ~us completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase ~from discovery .*.
- Example 1.3*3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3*3 may not be extended.
V (continued)
INDIAN POINT 3 Amencinent -f65-
LCO Applicability 3.0 LCO 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;
- 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 appropriat~ exceptions to this Specification are stated int individual Specification~or
- c. When an allowa ce is stated in the individual value, parameter, or o her Specification.
This Specification hall not prevent c anges in MODES or other specified con itions in the Appl cability that are required to comply ith ACTIONS or tha are part of a shutdown of the uni LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
(continued) u INDIAN POINT 3 3.0 - 2 Amendment~
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the perfonnance of the Surveillance or between perfonnances of the Surveillance, shall be failure to meet the LCO.
Failure to perfonn a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is perfonned within 1.25 times the interval specified in the Frequency, as measured from the previous perfonnance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per *** 11 basis, the above Frequency extension applies to each perfonnance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow perfonnance of the Surveillance. A risk evaluation shall be perfonned for any Surveillance d ayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 1
the risk impact shall be managed.
If the Surveillance is not perfo ed within the delay period, the LCO must imnediately be declared ot met, and the applicable Condition(s) must be entered.
When the Surveillance is perfonned within the delay period and the Surveillance is not met, the LCO m st imnediately be declared not met, and the applicable Condition(s must be entered.
The delay period is only
- - - - - - - - - - - - - - - - - - - - i a p p l i c a b l e when there is a reasonable expectation the (continued) u INDIAN POINT 3 3.0 - 4 surveillance will be met when performed.
Amendment z:t-r
ATTACHMENT 1.d CNR0-2019-00003 Markup of Technical Specification (TS) Pages Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20 TS Pages 1.3-1 3.0-2 3.0-5
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the plant. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the plant is in a MODE or specified condition stated in the Applicability of the
.------1--~*. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the plant is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition, otherwise c-n;:::.,.. ..1-,on Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, Palisades Nuclear Plant 1.3-1 Amendment No. 189
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 (continued)
- 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 appropriate7 (exceptions to this Specification are stated in the individual Specifications); or
- 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 plant.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
Palisades Nuclear Plant 3.0-2 Amendment No. 8-9, 219
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The is when is a l"O~>C-1"\n"ll'h!a exr)ec:tat1on rua, 11 1 0
will be met A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
Palisades Nuclear Plant 3.0-5 Amendment No. 489, 210
Insert 1 (TS 1.3, Completion Times, page 1.3-1)
(Note: The below paragraph will be added as a new separate paragraph between "LCO."
And "Required." This will result in splitting the existing paragraph into two separate paragraphs with the insert also a separate paragraph between them.)
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
ATIACHMENT 1.e CNR0-2019-00003 Markup of Technical Specification (TS) Pages River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Unit 1 TS Pages 1.0-11 3.0-2 3.0-4
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the tim~ of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires Insert 1 entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LC . Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.
Once a Condition has been entered, subsequent divisions, s bsystems, components, or variables expressed in the Condition, disco ered to be inoperable or not within limits, will not result in separate ent y into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with ompletion Times based on initial entry into the Condition.
(continued)
, unless otherwise specified RIVER BEND 1.0-11 Amendment No.
Insert 1 (TS 1.3, Completion Times, page 1.0-11)
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
LCO Applicablity 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessme addressing inoperable (continued) systems and components, considerati n of the results, determination of the acceptability of e tering the MODE or other specified condition in the Applicabilit and establishment of risk management actions, if appropriato/exceptions to this Specification are stated in the individual Specification~r
- c. When an allowance is stated in the individual value, pa other Specification.
This Specification shall not prevent changes in MODES or othe conditions in the Applicability that are required to comply with A or that are part of a shutdown of the unit.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
(continued)
RIVER BEND 3.0-2 Amendment No. 84, ~
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
t SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified 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 great than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk shall be managed.
If the Surveillance is not performed within the delay period, e LCO must immediately be declared not met, and the applicable Cond* ion(s) must be entered.
When the Surveillance is performed within the delay Surveillance is not met, the LCO must immediately and the applicable Condition(s) must be entered.
The delay period is only (continued) applicable when there is a reasonable expectation the surveillance will be met when performed.
RIVER BEND 3.0-4 Amendment No. 84, ~
ATIACHMENT 1.f CNR0-2019-00003 Markup of Technical Specification (TS) Pages Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Unit 3 TS Pages 3/4 0-2
~EPLICABILIJY
§URVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the Surveillance. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance. shall be failure to meet the LCO.
Failure to perform a Surveillance within the specified interval shall be failure to meet the LCO except as provided in 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 twenty-five percent of the specified surveillance interval.
4.0.3 If it is discovered that a Surveillance was not performed within its. specified interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hou and the risk impact shall be managed.
If the Survelllance Is not performed within the delay period, the LCO must I mediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Su eillance is not met, the LCO must immediately be declared not met, and the applicable ACTI (s) must be entered.
4.0.4 C::ntry into an Ol"ERATIONAL MODE or otherspecifiedcond' 10n sh;all not be made unless the Surveillance Requirement(s) associated with the Limiti Condition for Operation have been performed within the stated surveillance interval or as therwise specified. This provision shall not prevent passage through or to operational m des as required to comply with ACTION requirements.
The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.
WATERFORD UNIT 3 3/4 0-2 AMENDMENT N O . ~ ~
MAR 2 1 2003
ATTACHMENT 2.a CNR0-2019-00003 Clean Technical Specification (TS) Pages Arkansas Nuclear One, Unit 1 NRC Docket No. 50-313 Renewed Facility Operating License No. DPR-51 Unit 1 TS Pages 1.3-1 1.3-2 1.3-3*
1.3-4*
1.3-5*
1.3-6*
1.3-7*
1.3-8*
1.3-9*
1.3-10*
3.0-1 3.0-4
- Unit 1 TS Pages 1.3-3 through 1.3-1 Oare included due to repagination only.
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
AN0-1 1.3-1 Amendment No. 2-+a,
Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent train, subsystem, component, or variable, expressed in the Condition, is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
AN0-1 1.3-2 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times (continued)
DESCRIPTION (continued)
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
- 8. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.
The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition 8 was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AN0-1 1.3-3 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1. 3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.
- 8. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions 8.1 and 8.2 start. If the inoperable pump is restored to OPERABLE status after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated.
When a second pump is declared inoperable while the first pump is still inoperable, Condition A is not re-entered for the second pump.
LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition 8. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired.
AN0-1 1.3-4 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for> 7 days.
EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to train OPERABLE AND inoperable. status.
10 days from discovery of failure to meet the LCO B. One B.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to train OPERABLE AND inoperable. status.
10 days from discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X train to train OPERABLE inoperable. status.
AND OR One C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to OPERABLE train status.
AN0-1 1.3-5 Amendment No. ~ ,
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).
The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.
AN0-1 1.3-6 Amendment No. ~ ,
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1.3-4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve(s) to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE inoperable. status.
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times.
Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (plus the extension) expires while one or more valves are still inoperable, Condition B is entered.
AN0-1 1.3-7 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
EXAMPLE 1.3-5 ACTIONS
NOTE-------------------------------------------
S e para te Condition entry is allowed for each inoperable valve.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE inoperable. status.
B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.
The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis.
When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve.
AN0-1 1.3-8 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve.
Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.
EXAMPLE 1.3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.1 Perform Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. SR 3.x.x.x.
OR A.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to
~ 50% RTP.
B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated Completion Time not met.
Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance. The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval. If Required Action A.1 is followed and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2),
Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met, Condition B is entered.
If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A.
AN0-1 1.3-9 Amendment No. ~ .
Completion Times 1.3 1.3 Completion Times EXAMPLES (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Verify affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> subsystem subsystem isolated.
inoperable. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND A.2 Restore subsystem to OPERABLE 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> status.
B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" inteNal begins upon performance of Required Action A.1.
If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inteNal from the previous performance (plus the extension allowed by SR 3.0.2),
Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.
IMMEDIATE When "Immediately" is used as a Completion Time, the Required COMPLETION TIME Action should be pursued without delay and in a controlled manner.
AN0-1 1.3-10 Amendment No. ~ . ~ .
LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
- a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
- b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
- c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 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;
- 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 appropriate (exceptions to this Specification are stated in the individual Specifications), or AN0-1 3.0-1 Amendment No.~.~.~.~.
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
AN0-1 3.0-4 Amendment No.~.~,~.~.
ATTACHMENT 2.a (continued)
CNR0-2019-00003 Clean Technical Specification (TS) Pages Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 Unit 2 TS Pages 3/4 0-1 3/4 0-2
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation (LCO) and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification, except as provided in LCO 3.0.2, LCO 3.0.8, and LCO 3.0.9.
3.0.2 Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in Specification 3.0.6. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.
3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a mode in which the specification does not apply by placing it, as applicable, in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless corrective measures are completed that permit operation under the permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor is placed in a MODE in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specification.
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;
- 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 appropriate (exceptions to this Specification are stated in the individual Specifications), or
- 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.
ARKANSAS - UNIT 2 3/4 0-1 Amendment No. 4-B,434,~,284.
~.~.
APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the Surveillance.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified interval shall be failure to meet the LCO except as provided in 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 interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
4.0.4 Entry into a MODE or other specified condition in the Applicability shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided in 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 shall not prevent entry into 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.
ARKANSAS - UNIT 2 3/4 0-2 Amendment No. ~.~.4M.~.~.
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ATTACHMENT 2.b CNR0-2019-00003 Clean Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Unit 1 TS Pages 1.0-11 1.0-11 a*
3.0-2 3.0-4 3.0-4a*
- TS Pages 1.0-11a and 3.0-4a are new pages that have been added due to repagination.
Completion Times
- 1. 3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify m1n1mum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.
The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.
While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating,"
Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
(continued)
GRAND GULF 1.0-11 Amendment No. +/-re
Completion Times
1.3 DESCRIPTION
(continued)
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
(continued)
GRAND GULF 1.0-lla Amendment No.~
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) 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 (exceptions to this Specification are stated in the individual Specifications) ; or
- 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.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
(continued)
GRAND GULF 3.0-2 Amendment No. 2-, :rr SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . . " basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued)
GRAND GULF 3.0-4 Amendment No. 120
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued)
GRAND GULF 3.0-4a Amendment No. -iz-0 -3::-5-r
ATIACHMENT 2.c CNR0-2019-00003 Clean Technical Specification (TS) Pages Indian Point Nuclear Generating Unit 2 NRG Docket No. 50-247 Renewed Facility Operating License No. DPR-26 Unit 2 TS Pages 1.3-1 1.3-2 3.0-2 3.0-4
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time.
When in multiple Conditions, separate Completion Times are tracked for 1.3 each Condition starting from the time of discovery of the situation that required entry into the Condition, unless otherwise specified.
INDIAN POINT 2 1.3 - 1 Amendment No.
Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
INDIAN POINT 2 1.3 - 2 Amendment No.
LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 (continued)
- 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 appropriate (exceptions to this Specification are stated in the individual Specifications); or
- 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.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Technical Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
INDIAN POINT 2 3.0- 2 Amendment No.
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
INDIAN POINT 2 3.0-4 Amendment No.
ATIACHMENT 2.c (continued)
CNR0-2019-00003 Clean Technical Specification (TS) Pages Indian Point Nuclear Generating Unit 3 N RC Docket No. 50-286 Renewed Facility Operating License No. DPR-64 Unit 3 TS Pages 1.3-1 1.3-2 1.3-3*
1.3-4*
1.3-5*
1.3-6*
1.3-7*
1.3-8*
1.3-9*
1.3-1 O*
1.3-11
- 1.3-12*
1.3-13*
1.3-14**
3.0-2 3.0-4
- Unit 3 TS Pages 1.3-3 through 1.3-13 are included due to repagination only.
- Unit 3 TS Page 1.3-14 is a new page that has been added due to repagination.
Completion Times
- 1. 3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify m1n1mum requirements for ensuring safe operation of the unit.
The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating,"
Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)."
(continued)
INDIAN POINT 3 1. 3-1 Amendment
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times DESCRIPTION In this case the Completion Time does not begin until (continued) the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
(continued)
INDIAN POINT 3 1.3-2 Amendment
Completion Times
- 1. 3 1.0 USE AND APPLICATION 1.3 Completion Times DESCRIPTION The total Completion Time allowed for completing a (continued) Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications .
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... "
Example 1.3.3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3.3 may not be extended.
(continued)
INDIAN POINT 3 1. 3-3 Amendment
Completion Times 1.3 1.3 Completion Times (continued)
EXAHPLES The following examples illustrate the*use of Completion Times with different .types of Conditions and changing Conditions.
EXAMPLE 1,3*1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TI HE B. Required B.l Be in HOOE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated Mm Completion Ti me not met. B.2 Be in HOOE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition Bis entered.
The Required Actions of Condition Bare to be in HOOE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AHO in HOOE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching HOOE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching HOOE 5 from the time that Condition B was entered. If HOOE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. the time allowed for reaching HOOE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching HOOE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition Bis entered while in HOOE 3. the time allowed for reaching HOOE 5 is the next.36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
(continued)
INDIAN POitIT 3 1.3*4 Amen<inent
Completion Times 1.3 1.3 Completion Times u EXAHPLES EXAMPLE 1,3*2 (continued)
ACTIONS CONDITION REQUIRED ACTION COHPLETION TIHE A. One pump A.1 Restore pump to 7 days inoperable. OPERABLE status.
B. Required B.1 Be in HOOE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated Atill Completion Time not met. B.2 Be in HOOE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition Bis entered. Condition A and Bare exited, and therefore. the Required Actions of Condition B may be terminated.
When a second pump is declared inoperable while the first pump is
. I still inoperable, Condition A is not re-entered for the second pump .
LCO 3.0.3 is entered, since the ACT.IONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered, but continues to be tracked from the time Condition A was initially entered.
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition A.
(continued)
INDIAN POINT 3 1.3*5 Amenctnent
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1,3*2 (continued>
While in LCO 3.0.3, if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 ~ay be exited and operation continued in accordance with Condition B. The Completion Time for Condition Bis tracked from the time the Condition A Completion*Time expired.
On restoring one of the pumps to OPERABLE status. the Condition A Completion Time is not reset. but continues from the time the first pump was declared inoperable. This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed. provided this does not result in the second pump being inoperable for
> 7 days.
u (continued)
INDIAN POINT 3 1.3*6 Amenchent
Completion Times 1.3 1.3 Completion Times EXAHPLES EXAMPLE 1,3*3 (continued)
ACTIONS CONDITION REQUIRED ACTION COHPLETION TIME A. One Function X A.I Restore Function X 7 days train train to OPERABLE inoperable. status. AHO 10 days from discovery of failure to meet the LCO B. One Function Y B.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train train to OPERABLE inoperable. status. AHO 10 days from discovery of failure to meet the LCO C. One Function X C.l Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train train to OPERABLE inoperable. status.
~ OB One Function Y C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train train to OPERABLE.
inoperable. status.
(continued)
INDIAN POINT 3 1.3*7 Amencinent
Completion Times 1.3 1.3 Comeletion Times u EXAMPLES EXAMPLE 1.3-3 (continued)
When one Function X train and one Function V train are inoperable, Condition A and Condition Bare concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declar~d inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was.declared inoperable (i.e., the time the situation described in Condition C was discovered).
If Required Action C.2 is completed Within the specified Completion Time, Conditions Band Care exited. If the Completion Time for Required Action A.1 has not expired. operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A).
The Completion Times of Conditions A and Bare modified by a logical connector with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it ~ould be possible to V alternate between Conditions A. B. and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to*meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO.
This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as conmencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.
(continued)
INDIAN POINT 3 1.3*8 Amenonent
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1,3*4 (continued)
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIHE' A. One or more A.1 Restore valveCs) to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status.
B. Required B.1 Be in HOOE 3. 6 hours Action and associated HID Comp1eti on .
Time not met. B.2 Be in HOOE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable. while Condition A is still in effect, does not trigger the tracking of separate Completion Times.
Once one of the valves has been restored to OPERABLE status. the Condition A Completion Time is not reset. but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (including the extension) expires while one or more valves are still inoperable. Condition Bis entered.
(continued)
INDIAN POINT 3 1.3*9 Amenanent
Completion Times 1.3 1.3 Completion Times EXAHPLES EXAMPLE 1,3*5 (continued)
ACTIONS
......... --.... -. -* --* * * * * * * * **NOTE******************* * * * * * * * * * * * * *
- Separate Condition entry is allowed for each inoperable valve.
CONDITION REQUIRED ACTION COMPLETION TIHE A. One or more A.l Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status.
B. Required 8.1 Be in HOOE 3. 6 hours Action and associated AtID Completion Time not met. 8.2 Be in HOOE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> u
The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition. the Note would appear in that Condition rather than at the top of the ACTIONS Table.
The Note allows Condition A to be entered separately for each inoperable valve. and Completion Times tracked on a per valve basis.
When a valve is declared inoperable. Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable.* Condition A is entered for each vaive and separate Completion Times start and are tracked for each valve.
(continued)
\_)
INDIAN POINT 3 l.3*10 Amenanent
Completion Times 1.3 1.3 Comeletion Times EXAMPLES EXAMPLE 1.3*5 (continued)
If the Completion Time associated with a valve in Condition A expires. Condition Bis entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire.
Condition Bis entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition Bis restored to OPERABLE status.
Condition Bis exited for that valve.
Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.
EXAMPLE 1.3*6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel A.l Perform SR 3.x.x.x. Once per a hours inoperable.
08 A.2 Reduce lHERHAL POWER to s sot RTP. 8 hours B. Required B.l Be in HOOE 3. 6 hours Action and associated Completion Time not met.
(continued)
\_)
INDIAN POINT 3 l.3*11 Amencknent
- Completion Times 1.3 1.3 Comeletion Times EXAMPLES EXAMPLE 1,3-6 (continued)
Entry into Condition A offers a choice between Required Action A.l or A.2. Required Action A.1 has a "once per" Completion Time. which qualifies for the 25t extension. per SR 3.0.2. to each performance after the initial performance. The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.l begins when Condition A is entered and the initial performance of Required Action A.l must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval. If Required Action A.1 is followed. and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2), Condition Bis entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met. Condition Bis entered.
- If after entry into Condition B. Required Action A.1 or A.2 is met.
Condition Bis exited and operation may then continue in Condition A.
(continued)
INDIAN POINT 3 1.3*12 Amenanent
Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1,3*7 (continued)
ACTIONS CONDITION REQUIRED ACTION COHPLETION TIHE A. One subsystem A.l Verify affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. subsystem isolated.
MID Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter Ar:!.Q A.2 Restore subsystem to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.
B. Required B.l Be in HOOE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AMO Completion Time not met. B.2 Be in HOOE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter* interval begins upon performance of Required Action A.1.
(continued)
INDIAN POINT 3 l.3*13 Amenonent
Completion Times 1.3 1.3 Completion Times EXAHPLES EXAHPLE 1.3-7 (continued)
If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2). Condition Bis entered. The Completion Time clock for Condition A does not stop after Condition Bis entered. but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition Bis entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.
IHHEDIATE COMPLETION TIHE When "Ifll'llediately" is used as a Completion Time. the Required Action should be pursued without delay and in a controlled manner.
u INDIAN POINT 3 1.3*14 Amenanent
LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)
LCO 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;
- 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 appropriate (exceptions to this Specification are stated in the individual Specifications); or
- 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.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.14, "Safety Function Determination Program (SFDP)". If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
(continued)
INDIAN POINT 3 3.0 - 2 Amendment
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . " basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.
A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
INDIAN POINT 3 3.0 - 4 Amendment
ATIACHMENT 2.d CNR0-2019-00003 Clean Technical Specification (TS) Pages Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20 TS Pages 1.3-1 1.3-2 1.3-3*
3.0-2 3.0-5
- TS Page 1.3-3 is included due to repagination only.
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the plant. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,
inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the plant is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the plant is not within the LCO Applicability.
If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the Palisades Nuclear Plant 1.3-1 Amendment No. 48-9, XXX
Completion Times 1.3 1.3 Completion Times DESCRIPTION associated Completion Time. When in multiple Conditions, separate (continued) Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of Palisades Nuclear Plant 1.3-2 Amendment No. 488, XXX
Completion Times 1.3 1.3 Completion Times DESCRIPTION this type of Completion Time. The 10 day Completion Time specified for (continued) Conditions A and 8 in Example 1.3-3 may not be extended.
EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.
EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
- 8. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.
The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Palisades Nuclear Plant 1.3-3 Amendment No. 489, XXX
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 (continued)
- 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 appropriate (exceptions to this Specification are stated in the individual Specifications); or
- 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 plant.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
Palisades Nuclear Plant 3.0-2 Amendment No. ~ . XXX
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
Palisades Nuclear Plant 3.0-5 Amendment No. ~ . XXX
ATIACHMENT 2.e CNR0-2019-0000 3 Clean Technical Specification (TS) Pages River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Unit 1 TS Pages 1.0-11 1.0-12 1.0-12a*
3.0-2 3.0-4
- TS Page 1.0-12a is a new page that has been added due to repagination.
Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,
inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.
Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.
(continued)
RIVER BEND 1.0-11 Amendment No. 84
Completion Times
1.3 DESCRIPTION
If situations are discovered that require entry into more than one condition (continued) at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.
However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:
- a. Must exist concurrent with the first inoperability; and
- b. Must remain inoperable or not within limits after the first inoperability is resolved.
The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:
- a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The stated Completion Time as measured from discovery of the subsequent inoperability.
The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.
(continued)
RIVER BEND 1.0-12 Amendment No. 84
Completion Times
1.3 DESCRIPTION
The above Completion Time extension does not apply to a Completion (continued) Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3-3 may not be extended.
(continued)
RIVER BEND 1.0-12a Amendment No. 84, 4W
LCO Applicablity 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) 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 (exceptions to this Specification are stated in the individual Specifications); or
- 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.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
(continued)
RIVER BEND 3.0-2 Amendment No. 84, 4ae
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... "
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued)
RIVER BEND 3.0-4 Amendment No. 84, 4U
ATTACHMENT 2.f CNR0-2019-00003 Clean Technical Specification (TS) Pages Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Unit 3 TS Pages 3/4 0-2
e,eeucABILITY , ..
§URVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the Surveillance. Failure to meet a Surveillance, whether such failure is experienced during the perfonnance of the Surveillance or between performances of the Surveillance. shall be failure to meet the LCO.
Failure to perform a Surveillance within the specified interval shalt be failure to meet the LCO except as provided in 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 twenty-five percent of the specified surveillance interval.
4.0.3 If It is discovered that a Surveillance was not performed within its. specified interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Survelllance Is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.
4.0.4 Entry into an OPERATIONAL MODE or otherEpecifiedcondition s:h:all not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to operational modes as required to comply with ACTION requirements.
WATERFORD UNIT 3 3/4 0-2 AMENDMENT NO. ~ -ter-lAAR 2 1 2003
ATIACHMEN T 3.a CNR0-2019-0 0003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Arkansas Nuclear One, Unit 1 NRC Docket No. 50-313 Renewed Facility Operating License No. DPR-51 Unit 1 TS Bases Pages B 3.0-1 B 3.0-2 B 3.0-4 B 3.0-5 B 3.0-7 B 3.0-8 B 3.0-16 B 3.0-17 83.0-18
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
- a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specification.
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."
AN0-1 B 3.0-1 Amendment No. 215 Rev. ~.~.e4,
LCO Applicability B 3.0 BASES LCO APPLICABILITY (continued)
LCO 3.0.3 Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown (continued) before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enterfeaffi lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
- a. The LCO is now met-=-
- b. The LCO is no longer applicable, g_b. A Condition exists for which the Required Actions have now been performed, or-:-
ge. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for enteringreaching the next lower MODE applies. If a lower MODE is enteredreached in less time than allowed, however, the total allowable time to enterfeaffi MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is enteredreached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for enteringreaching MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for entereingreaching MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enterfeaffi a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
AN0-1 B 3.0-2 Amendment No. 215 Rev. -24,
LCO Applicability B 3.0 BASES LCO APPLICABILITY (continued)
LCO 3.0.3 Exceptions to LCO 3.0.3 are provided in instances where requiring a unit (continued) shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.13, "Spent Fuel Pool Water Level." LCO 3.7.13 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3. 7 .13 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.13 of "Suspend movement of irradiated fuel assemblies in the spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry intopermit continued operation in the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with ACTIONSRequired 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 and the Required Actions followed after entry into the Applicabilityin accordance
'Nith the provisions of the Required Actions. 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.
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.
AN0-1 B 3.0-4 Amendment No. 215 Rev.~.~.
LCO Applicability B 3.0 BASES LCO APPLICABILITY (continued)
LCO 3.0.4 If the instrument channel cannot be placed in the tripped condition and the (continued) 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.
LCO 3.0.4.b allows entry into a MODE or other specified condition 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 TS 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 (RG) 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." RG 1.160 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 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.
AN0-1 B 3.0-5 Amendment No. 215 Rev. ~.~,49,
LCO Applicability B 3.0 BASES LCO APPLICABILITY (continued)
LCO 3.0.4 Upon entry into a MODE or other specified condition in the Applicability with the (continued) 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 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on 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.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls 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 required testing to 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 required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System
{RCS) Pressure Isolation Valve {PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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.
AN0-1 B 3.0-7 Amendment No. 215 Rev. 2-1-.~.
LCO Applicability B 3.0 LCO 3.0.5 An example of demons trating the OPERA BILITY of the equipme nt being (continue d) returned to service is reopenin g a containm ent isolation valve that has been closed to comply '.vith Required Actions and must be reopene d to perform the required testing.
AA-.f;example§ of demons trating the OPERA BILITY of other equipme nt are+s taking an inoperab le channel or trip system out of the tripped condition 1.}_to prevent the trip function from occurrin g during the performa nce of required testing on another channel in the other trip system.i.-m:.12. /\ similar example of demons trating the OPERA BILITY of other equipme nt is taking an inoperab le channel or trip system out of the tripped condition to permit the logic to function and indicate the appropri ate response during the performa nce of required testing on another channel in the same trip system.
The administ rative controls in LCO 3.0.5 apply in all cases to systems or compon ents in Chapter 3 of the Technic al Specifications. as long as the testing could not be conduct ed while complyin g with the Required Actions. This includes the realignm ent or repositioning of redunda nt or alternate equipme nt or trains previous ly manipul ated to comply with ACTION S. as well as equipme nt removed from service or declared inoperab le to comply with ACTION S.
LCO 3.0.6 LCO 3.0.6 establish es an exceptio n to LCO 3.0.2 for support systems that have an LCO specified in the Technic al Specific ations (TS). This exceptio n is provided because LCO 3.0.2 would require that the Conditio ns and Required Actions of the associat ed inoperab le supporte d system LCO be entered solely due to the inoperab ility of the support system. This exceptio n is justified because the actions that are required to ensure the unit is maintain ed in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supporte d system's Conditio ns and Required Actions or may specify other Required Actions.
When a support system is inoperab le and there is an LCO specified for it in the TS, the supporte d system( s) are required to be declared inoperab le if determin ed to be inoperab le as a result of the support system inoperability. Howeve r, it is not necessa ry to enter into the supporte d systems ' Conditio ns and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsis tency of requirem ents related to the entry into multiple support and supporte d systems ' LCOs' Conditio ns and Required Actions are eliminate d by providing all the actions that are necessa ry to ensure the unit is maintain ed in a safe condition in the support system's Required Actions.
Howeve r, there are instance s where a support system's Required Action may either direct a supported system to be declared inoperab le or direct entry into Conditio ns and Required Actions for the supporte d system. This may occur immedia tely or after some specified delay to perform some other Required Action. Regardle ss of whether it is immedia te or after some delay, when a support system's Required Action directs a supporte d system to be declared inoperab le or directs entry in Conditio ns and Required Actions for a supporte d system, the applicab le Conditio ns and Require d Actions shall be entered in accorda nce with LCO 3.0.2.
AN0-1 B 3.0-8 Amendm ent No. 215 Rev.~ .~.
SR Applicability B 3.0 BASES SR APPLICABILITY (continued)
SR 3.0.2 The 25% extension does not significantly degrade the reliability that results from (continued) performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Examples of where SR 3.0.2 does not apply are the Reactor Building Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot, in and of themselves, extend a test interval specified in the regulations directly or by reference.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%
extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performedcompleted within the specified Frequency.
A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
AN0-1 B 3.0-16 Amendment No. 215,217 Rev. ~.~.~.&1-,
SR Applicability B 3.0 BASES SR APPLICABILITY (continued)
SR 3.0.3 When a Section 5.5, "Programs and Manuals," specification states that the (continued) provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 specification).
This delay period provides an adequate time to performcomplete Surveillances that have been missed. This delay period permits the performancecompletion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performancecompletion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operational 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 3.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance.
However, where a time interval is not specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 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 ever been performed, and any other indications. tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment from the performance of similar equipment.
AN0-1 B 3.0-17 Amendment No. 215,217 Rev. 24,~,49.~,&1-,
SR Applicability B 3.0 BASES SR APPLICABILITY (continued)
SR 3.0.3 The rigor of determining whether there is a reasonable expectation a (continued) 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedlyas an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the 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 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, 'Monitoring the Effectiveness of Maintenance at 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 Surveillances 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's Corrective Action Program.
AN0-1 B 3.0-18 Amendment No. 215,217 Rev. ~,~,49,aS,e ,
ATTACHMENT 3.a (continued)
CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 Unit 2 TS Bases Pages B 3/4 0-1 B 3/4 0-2 B 3/4 0-3 B 3/4 0-4 B 3/4 0-5 B 3/4 0-7 B 3/4 0-8 B 3/4 0-14 B 3/4 0-15
3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs 3.0.1 through LCO 3.0.6, LCO 3.0.8, and LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e.,
when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The allowable outage time (AOT) of each ACTION is applicable from the point in time that an ACTION is entered, unless otherwise specified. The ACTIONS establish those remedial measures that must be taken within specified AOTs when the requirements of an LCO are not met.
This Specification establishes that:
- a. Completion of the ACTIONS within the specified AOTs constitutes compliance with a Specification and
- b. Completion of the ACTIONS is not required when an LCO is met within the specified AOT, unless otherwise specified.
There are two basic types of ACTIONS. The first type of ACTION specifies a time limit in which the LCO must be met. This time limit is the AOT to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of ACTION is not completed within the specified AOT, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as an ACTION or not, correction of the entered condition is an action that may always be considered upon entering ACTIONS.) The second type of ACTION specifies the remedial measures that permit continued operation of the unit that is not further restricted by the AOT. In this case, compliance with the ACTION provides an acceptable level of safety for continued operation.
The nature of some ACTIONS necessitate that, once the ACTION is entered, the ACTION must be completed even though the associated condition no longer exists. An example of this is in LCO 3.4.9.1, RCS Pressure/Temperature Limits.
The time limits of the ACTIONS requirements are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.
ARKANSAS - UNIT 2 B 3/4 0-1 Amendment No. 19,134 Rev. ~.48,e+,
LCO APPLICABILITY BASES LCO 3.0.2 (continued)
Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual specifications may specify a time limit for performing a Surveillance when equipment is removed from service or bypassed for testing. In this case, the AOTs of the ACTIONS are applicable when this limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with ACTIONS, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the AOTs of the associated ACTIONS would apply from the point in time that the new Specification becomes applicable if the ACTIONS are entered.
LCO 3.0.3 LCO 3.0.3 establishes the ACTIONS that must be implemented when an LCO is not met and either:
- a. An associated ACTION and AOT is not met and no other ACTION applies or
- b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of ACTIONS are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, one hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enterfeaGh lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions for which this Specification applies.
ARKANSAS - UNIT 2 B 3/4 0-2 Amendment No. 19,134 Rev. ~.~.4i,
LCO APPLICABILITY BASES LCO 3.0.3 (continued)
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
- a. The LCO is now met,
- b. The LCO is no longer applicable,
.Qb. An ACTION exists for which the ACTIONS have now been performed, or gs. ACTIONS exist that do not have expired AOTs. These AOTs are applicable from the point in time that the ACTION is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for the plant to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for enterfeaBl::l.ing the next lower MODE applies. If a lower MODE is feaBl::l.entered in less time than allowed, the total allowable time to enterfeaBl::l. MODE 5 or other applicable MODE, is not reduced. For example, if MODE 3 is reachentered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for feaBl::l.entering MODE 4 is the next 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, because the total time to enteringraaoo MODE 4 is not reduced from the allowable limit of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enterfeaBl::l. a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.9.10, "Spent Fuel Pool Water Level." LCO 3.9.10 has an Applicability of "Whenever irradiated fuel assemblies are in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the ACTION of LCO 3.9.10 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by placing the unit in a COLD SHUTDOWN condition. The LCO 3.9.10 ACTION of "suspend all movement of fuel assemblies and crane operations with loads in the spent fuel pool areas and restore the water level to within its limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />" is the appropriate ACTION to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
ARKANSAS - UNIT 2 B 3/4 0-3 Amendment No. 19,134 Rev.4,~,~,
LCO APPLICABILITY BASES LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry intopermit continued operation in the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with 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 and the ACTIONS followed after entry into the Applicabilityin accordance with the provisions of the ACTIONS.
For example, LCO 3.0.4.a may be used when ACTION to be entered states that an inoperable instrument channel must be placed in the trip condition within the AOT. 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 AOT. which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION (where the ACTION was not met within the AOT) 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.
LCO 3.0.4.b allows entry into a MODE or other specified condition 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 TS 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 (RG) 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power ARKANSAS - UNIT 2 B 3/4 0-4 Amendment No. 134,234 Rev. 4,~,4,g,a4,
LCO APPLICABILITY BASES LCO 3.0.4 (continued)
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 TSs allow continued operation with equipment unavailable in MODE 1 for the duration of the AOT. 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 (LCO 3.4.12 - LTOPS, LCO 3.5.3 -
ECCS when entering MODE 4, LCO 3.7.1.2 - EFW, LCO 3.8.1.1 - EDGs) 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 a Note 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 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 which describe values and parameters (e.g., RGS Chemistry, RCS Specific Activity), 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 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 in 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.
ARKANSAS - UNIT 2 B 3/4 0-5 Amendment ~Jo. 134 Rev. ~.48,
LCO APPLICABILITY BASES LCO 3.0.5 (continued)
As a further example, LCO 3.8.1.1 requires, in part, two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system to be OPERABLE. The ACTION provides a 24-hour AOT when both required offsite circuits are inoperable. If the definition of OPERABLE were applied without consideration of LCO 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable normal power sources, both of the offsite circuits, would also be inoperable. This would dictate invoking the applicable ACTIONS for each of the applicable LCOs. However, the provisions of LCO 3.0.5 permit the time limits for continued operation to be consistent with the ACTION for the inoperable normal power sources instead, provided the other specified conditions are satisfied. In this case, this would mean that for one train the emergency power source must be OPERABLE (as need be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other train must be OPERABLE, or likewise satisfy LCO 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both trains must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this Specification.
In MODES 5 OR 6, LCO 3.0.5 is not applicable, and thus the individual ACTIONS for each applicable LCO in these MODES must be adhered to.
LCO 3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service under administrative controls 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 ACTIONS) to allow the performance of required testing to demonstrate either:
- 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 required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.6 should not be used in lieu of other practicable alternatives that comply with ACTIONS and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.6 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the ACTIONS not met is opening a manual valve that was closed to comply with ACTIONS to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure ARKANSAS - UNIT 2 B 3/4 0-7 Amendment No. 103,134,207,233,246 Rev. ~.de,~,
Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply 1Nith ACTIONS and must be reopened to perform the required testing.
Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by an ACTION, if there is no ACTION Note for this purpose. An example of verifying OPERABILITY 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.
ARKANSAS- UNIT 2 B 3/4 0-7 Amendment ~Jo. 103,134,207,233,246 Rev. ~.~.48.
LCO APPLICABILITY BASES LCO 3.0.6 (continued)
AR-!;_example§ of demonstrating the OPERABILITY of other equipment are+s taking an inoperable channel or trip system out of the tripped condition 1}_to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system~. /\ similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
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 ACTIONS. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
LCO 3.0.7 (later)
LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the TS under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36, and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the ACTIONS entered in accordance with LCO 3.0.2.
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72-hour AOT is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
ARKANSAS - UNIT 2 B 3/4 0-8 Amendment No. 246 Rev. ~.Je.~.~.
SR APPLICABILITY BASES SR 4.0.2 (continued)
As stated in SR 4.0.2, the 25% extension also does not apply to the initial portion of a periodic AOT that requires performance on a "once per ... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the ACTION, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single AOT. One reason for not allowing the 25% extension to this AOT is that such an ACTION usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 4.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic AOT intervals beyond those specified.
SR 4.0.3 SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performedcompleted within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 4.0.2, and not at the time that the specified Frequency was not met.
When a Section 6.5, "Programs and Manuals," specification states that the provisions of SR 4.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 4.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 4.0.2 if invoked by the Section 6.5 specification).
This delay period provides an adequate time to performcomplete Surveillances that have been missed. This delay period permits the performancecompletion of a Surveillance before complying with ACTIONS or other remedial measures that might preclude performancecompletion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with an interval based not on time intervals, but upon specified unit conditions, operational 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 full delay period of up to the specified Frequency to perform the Surveillance. 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 ACTIONS.
ARKANSAS - UNIT 2 B 3/4 0-14 Amendment No. 134,233,246 Rev. ~,~,4,g,e4,97,
SR APPLICABILITY BASES SR 4.0.3 (continued)
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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 4.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact the adiacent, 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used repeatedlyas an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the 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 CFR 50.65(a)(4) and its implementation guidance, NRC RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This RG 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 RG. 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 Surveillances 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's Corrective Action Program.
ARKANSAS - UNIT 2 B 3/4 0-15 Rev. Je,48,a4,e-7,
ATIACHMENT 3.b CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Unit 1 TS Bases Pages B 3.0-1 B 3.0-3 8 3.0-4 8 3.0-5 B 3.0-7 B 3.0-12 B 3.0-13
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial sures that must be taken within specified Completion mes when the requirements of an LCO are not met. Th' Specification establishes that:
- a. Com etion of the Required Actions within the ecified Completion Times constitutes compliance with a Specification; and
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the (continued)
GRAND GULF B 3.0-1 LBDCR 16001
LCO Applicability B 3.0 BASES (continued)
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
- a. An associated Required Action and Completion Time is not met and no other Condition applies; or
- b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual
- condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be mai.ntained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. jenter I Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare fr an orderly shutdown before initiating a change in unit .
operation. This includes time to permit the operator o coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availab11* y of the electrical grid. The time limits specified to--A11K;f1-lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and*-
interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
(continued)
GRAND GULF B 3.0*3 Revision No.~
LCO Applicability B 3.0 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:
- a. The LCO is now me~
A Condition exists f which the Required Actions have now been performe~
ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required durin.,.__..............,
entering MODE 1 operation. If the unit is in a lower MOOE of operation when a shutdown is required, the tim or
~iil-GA--l-1°w the next lower MOOE app 1i es. ower MODE is entered
~ in less time than a , owever, the total
.---~---.~ ~~!o~~~1e time to 0~ 4, or ot~er applic ~l.,__.....,~~L, is ntered not reduced. For example, 1f MODE 2 1s 1n 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, .--e-nt-er-in_g......,
then the time allowed for MOOE 3 is the ne 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because otal time for
- 3 is not reduced fr e allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if re measures are completed that would permit a return entering o MOOE I, a penalty is not incurred by having to a lower MOOE of operation in less than the total time allo In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.6, "Fuel Pool Water level." LCO 3.7.6 has an Applicability of "During movement of irradiated fuel (continued)
GRANO GULF B 3.0-4 Revision No.~
LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the associated fuel storage pool." Therefore, (continued) this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.6 are not met while in MODE l, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.6 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MOOE or other eithe specified condition stated in that Applicability (e.g., the icability desired to be entered) when unit conditions the requirements of the LCO would not be met, LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit canti 011ed operation
- the MODE or other specified condition in the will permit continued 1---~-,,,.,.i..4,H-+<c,~++t-v-1~for an unlimited period of time. Compliance operation within the
~~.__._.____......i.-l~.... that permit continued operation of the MODE or other specified condition uni or an unlimited period of time in a MODE or other ecified 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 and the Required Actions specified condition in the Applicabi1ity may be made~
followed after entry into accordaRce with the provisions of the Required Actions.
the Applicability.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after Insert 1 performance of a risk assessment addressing inoperable (as new paragraph) 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 GRAND GULF B 3.0-5 LDC e+9-r&
Insert 1 (TS Bases LCO 3.0.4, page B 3.0-5)
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 in 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.
LCO Applicability 8 3.0 BASES LCO 3.0.5 provide an exception to LCO 3.0.2 (e.g., to not comply with (continued} the applicable Required Action(s)) to allow the performance of SRs to demonstrate:
- a. The OPERABILITY of the equipment being returned to service; or Insert
- 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 ONS is limited to the time absolutely necessary to per the allowed SRs. This Specification does not provide
- e to perform any other preventive or corrective maintenance An example ef demenstratiAg the OPERABILITY ef the e~uipment being returned tg service is reopeRiAg a ceAtaiRmeRt iselatian valve that has eeeR clesea to cemply with Reqwirea Aetians, and must be reepened te perfe'f"ffl the SRs.
~IHKRIR+A of demonstrating the OPERABILITY of other e taking an inoperable channel or trip system out of the tripped condi
- to prevent the trip function from occurr*
- g he performance of an SR on another channel 1 n the oth~ r tr i p system ~.,,....,1r1.r-Ht++...~~IU-f-!~4-Insert 4 (new paragraph)
LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.
(continued)
GRAND GULF 8 3.0-7 Revision No.~
Insert 2 (TS Bases LCO 3.0.5, page B 3.0-7)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Insert 3 (TS Bases LCO 3.0.5, page B 3.0-7)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 4 (TS Bases LCO 3.0.5, page B 3.0-7)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the (continued) reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. For example, the requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations. Therefore, there is a Note in the Frequency stating, "SR 3.0.2 is not applicable."
When a Section 5.5, "Programs and Manuals," specification states that the provisions of SR 3.0.2 are applicable, a 25% extension of the testing interval, whether stated in the specification or incorporated by reference, t
is permitted.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly mEm~ly as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment ble or an affected variable outside the specified limits when a Surveillance has no within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the (continued)
GRAND GULF B 3.0-12 LBDCR 16010
SR Applicability B 3.0 BASES SR 3.0.3 time that the specified Frequency was not met.
(continued)
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits ompletion of a Surveillance before co *
- equired Actions or other remedial m.e~J.res-ttrarm1ght rec of the Surveillance.
performance When a Section 5.5, "Programs and Manuals," specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by Section 5.5 specification).
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a 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 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE Insert 5 (new changes imposed by Required Actions.
paragraph)
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational
~mv:eR-1e*~e. to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed repeatedly 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
( continued)
GRAND GULF 8 3.0-13 LBDCR 15010
Insert 5 (TS Bases SR 3.0.3, page B 3.0-13)
SR 3.0.3 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
ATTACHM ENT 3.c CNR0-201 9-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Indian Point Nuclear Generating Unit 2 N RC Docket No. 50-247 Renewed Facility Operating License No. DPR-26 Unit 2 TS Bases Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-6 B 3.0-7 B 3.0-8 B 3.0-15 B 3.0-16
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that e taken within specified Completion Times when the nts of an LCO are not met. This Specification establishe
, unless otherwise specified Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
INDIAN POINT 2 B 3.0 - 1 RevisionY
LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
- b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS.
It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly down before initiating a change in unit operation. This includes time to permit t ator to coordinate the reduction in electrical generation with the load dispatcher sure the stability and availability of the electrical grid. The time limits specified lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
- b. The LCO is no longer applicable, The LCO is now met, A Condition exists for which the Required Actions have now been performed, or ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
INDIAN POINT 2 B 3.0 - 3 RevisionY
LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for th unit to be in M DE 5 when a shutdown is required during MODE 1 opera ion. If the nit i in a lower MODE of operation when a shutdown is requi d, the ti e Ii it for
~reaching the next lower MODE applies. If a lower MO is in less
---/ time than allowed, however, the total allowable time to t=ea4 MODE , or
- able MODE, is not reduced. For example, if MODE 3 is~:ieA-ee-in , the time a o
- MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time o reaching MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to Feama lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.11, "Spent Fuel Pit Water Level." LCO 3.7.11 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pit." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3. 7 .11 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.11 of "Suspend movement of irradiated fuel assemblies in the spent fuel pit" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3.
These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g.,
either the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
INDIAN POINT 2 B 3.0- 4 RevisionY
LCO Applicability B 3.0 ACTIONS BASES LCO 3.0.4 (continued)
!following entry into ! ~ C O 3.0.4.a allows entry into a MODE or other specified con ition in the
- cability with the LCO not met when the associated ACTI NS to be entere permit eontinued operation in the MODE or other specified ondition in the Applicabili for an unlimited period of time. Compliance with Re~uired Actions th rmit continued operation of the unit for an unlimited period of time i ODE or other specified condition provides an acceptable level of will permit continued ety for continued operation. This is without regard to the status of the unit operation within the MODE or other before or after the MODE change. Therefore, in such cases, entry into a specified condition MODE or other specified condition in the Applicability may be made-tA-and the Required Actions followed LCO 3.0.4.b allows entry into a MODE or other specified condition in the after entry into Applicability with the LCO not met after performance of a risk assessment Applicability 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.
Insert 1 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 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 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 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.
INDIAN POINT 2 B 3.0 - 5 Revision~
Insert 1 (TS Bases LCO 3.0.4, page B 3.0-5)
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 in 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.
LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
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 a Note 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 which describe values and parameters (e.g., RCS ~"1"'tflf"'::"
Activity), and may be applied to other Specifications based n NRC plant-specific approval. Speci 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.
INDIAN POINT 2 B 3.0 - 6 RevisionY
LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
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 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 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 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.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls 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 required testing to demonstrate either:
- 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 required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.
INDIAN POINT 2 B 3.0 - 7 RevisionY
Insert 2 (TS Bases LCO 3.0.5, page 8 3.0-7)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
.An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
~~QA~3- of demonstrating the OPERABILITY of other equipment-+&--
taking an inoperable channel or trip system out of the tripped condition prevent the trip function from occurring during the performance of require testing on another channel in the other trip systerl)r A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable cl ,a, uiel or trii, s~stem out of the tripped coRdition permit the logic to function and indicate the appropriate response during e performance of
~ e q u i r e d testing on another channel in the same trip syste . , or )
2 LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.
When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability.
However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.
INDIAN POINT 2 B 3.0 - 8 Revision A""'
Insert 3 (TS Bases LCO 3.0.5, page B 3.0-8)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 4 (TS Bases LCO 3.0.5, page B 3.0-8)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
SR Applicability B 3.0 BASES SR 3.0.2 (continued)
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency.
This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25%
extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations. As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ... " basis. The 25% extension applies to each performance after the initial performance.
The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%
extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an or,erational eenvenienee to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been within the specified Frequency. A delay period of up to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies rom the point in time that it is discovered that the Surveillance has not be performed in accordance with SR 3.0.2, and not at the time that the spe ified Frequency was not met.
performed INDIAN POINT 2 B 3.0 - 15 Revision%
SR Applicability B 3.0 perform BASES SR 3.0.3 (continued)
This delay period provides adequate time to Surveillances that have been missed. This delay period permits the of a Surveillance before complying with Required Actions or othe remedial measures that might preclude
- the Surveillance.,_ ___._ _-
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a 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 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes ert 5 imposed by Required Actions. edly Failure to comply with specified Frequencie for SRs is expected to be an infrequent occurrence. Use of the delay peri d established by SR 3.0.3 is a flexibility which is not intended to be used as an operational com:enionce to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the 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 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk INDIAN POINT 2 B 3.0 - 16 Revision%
Insert 5 (TS Bases SR 3.0.3, page B 3.0-16)
SR 3.0.3 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entere The Required Actions establish those remedial meas at must be taken within specified Completion Time he requirements of an LCO are not met. This S *
- ation establishes that:
, unless otherwise specified a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met.
This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)
(continued)
INDIAN POINT 3 B 3.0 - 1 Revision;t
LCO Applicability B 3.0 BASES LCO 3.0.2 In this case, the Completion Times of the associated Required (continued) Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
- a. An associated Required Action and Completion Time is not met and no other Condition applies; or
- b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly enter shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in e rical generation with the load dispatcher to ensure the stabili nd availability of the electrical grid. The time limits specified to lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE.
(continued)
INDIAN POINT 3 B 3.0 - 3 Revision.,-3"'
LCO Applicability B 3.0 BASES LCO 3.0.3 This reduces thermal stresses on components of the Reactor (continued) Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
- b. The LCO is no a. The LCO is now me~
longer applicable,
)r. A Condition exists for which the Required Actions have now been performe~
ACTIONS exist that do not have expired Completion Times.
These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of Specificati n 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shut wn is require during MODE 1 operation.
If the unit is in a lower ODE of operatio when a shutdown is required, the time limi for reaching the ext lower MODE applies.
If a lower MODE is in le s time th n allowed, however, the fueft MOE 5, or o er applicable MODE, is no or example, if MOE 3 is reacAed in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total ODE 4 i not reduced from the allowable re ore, if remedial measures are completed incurred by of operation in less than the total In MODES l, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
(continued)
INDIAN POINT 3 B 3.0 - 4 Revision ;f
LCO Applicability B 3.0 BASES LCO 3.0.3 Exceptions to LCO 3.0.3 are provided in instances where requ1r1ng (continued) a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Spent Fuel Pit Water Level. 11 LCO 3. 7 .14 has an Appl i cabi 1i ty of 11 Duri ng movement of irradiated fue 1 assemb 1i es in the Spent Fue 1 Pit. 11 Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in the Spent Fuel Pit" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is n met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicabilit desired to be entered) when unit conditions are such that th requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
following entry int CO 3.0.4.a allows entry into a MODE or other specified condition in
- cability with the LCO not met when the associated ACTIONS to be entere per~it contin~ed operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance hat permit continued o the unit for an unlimited p riod of time in a MODE or ACTIONS specified condition provides an ace ptable level of safety for continued operation. This is without reg rd to the status of the unit before or after the MODE change. Th refore, in such cases, entry into a MODE or other specified condition the Applicability may be made ~*~1-&E-B-R~I-E--w.:1~-t-1~-H-r -~~-HH-s-frf--f:.FH~..ee-H-+-i~
3.0.4.b allo sentry into a MODE or ot er specified condition in the Applicability with the LCO not met afte performance of a risk assessment address*ng inoperable systems an components, consideration of th results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of isk management actions, if appropriate.
and the Required will permit continued Actions followed operation within the after entry into MODE or other (continued)
i Applicability specified condition INDIAN POINT 3 B 3.0 - 5 Revision ;t
Insert 1 (TS Bases LCO 3.0.4, page B 3.0-5)
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 in 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.
LCO Applicability B 3.0 BASES LCD 3.0.4 should be generally acceptable, as long as the risk assessed and (continued) 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 the use of the LCD 3.0.4.b allowance is prohibited. The LCOs governing these systems 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 a Note in the Specification which states LCD 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 pecific Activit 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 which describe values and parameters (e.g., RCS
-G-FW~~F---r1~~~), 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 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 un:i-t- 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 in to 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.
(continued)
INDIAN POINT 3 B 3.0 - 7 Revision%
LCO Applicability B 3.0 BASES LCO 3.0.4 Surveillances do not have to be performed on the associated (continued) inoperable equipment (or on variables outside the specified limits),
as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 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.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls 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 required testing to 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 iA coAflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.
AA example of demonstrating tRe OPERAaibITY of the equipment being
,ettl,ned te se, oiee is reopeAing a containment isolation valve tRat has been closed to comply with Req~ired Actions and m~st be reopened rt 3 to ~e,forffi tRc SRs.
"H=l-8i3,e&--&EHTS~rS-R to permit the logic to function and indicate the response during the performance of required testing on another hannel in the same trip system.
, or 2)
(continued)
INDIAN POINT 3 B 3.0 - 8 Revision,Y
Insert 2 (TS Bases LCO 3.0.5, page B 3.0-8)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Insert 3 (TS Bases LCO 3.0.5, page B 3.0-8)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 4 (TS Bases LCO 3.0.5, page B 3.0-8)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
SR Applicability B 3.0 BASES SR 3.0.2 The exceptions to SR 3.0.2 are those Surveillances for which the (continued) 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications.
An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of in accordance with 10 CFR 50, Appendix J, as modified 11 by approved exemptions. 11 The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations. Therefore, there is a Note in the Frequency stating, SR 3.0.2 is not applicable.
11 11 As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ... basis. The 25% extension applies to 11 each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as aR operatioRal coRveAieAce to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, which er is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3 0.2, and not at the time that the specified Frequency was not met.
1 This delay period provides adequate ime that have been missed.
performed perform (continued)
INDIAN POINT 3 B 3.0 - 15 Revision}(
SR App 1i cabil i ty B 3.0 BASES SR 3.0.3 This delay period ermits the of a Surveillance before (continued) complying with R uired Actions or other remedial measures that might preclude complet10R of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a 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 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
Insert 5 Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an "flfl1~rf:+fifl-i'H-~R-¥-f~~~ to extend Surveillance intervals.
peatedly While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the 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 CFR 50.56(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and 1
Managing Risk Before Maintenance Activities at Nuclear Power Plants. 1 This Regulatory Guide addresses consideration of temporary and (continued)
INDIAN POINT 3 B 3.0 - 16 Revision,,Z'
Insert 5 (TS Bases SR 3.0.3, page B 3.0-16)
SR 3.0.3 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
ATTACHMENT 3.c (continued)
CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Indian Point Nuclear Generating Unit 3 NRC Docket No. 50-286 Renewed Facility Operating License No. DPR-64 Unit 3 TS Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-7 B 3.0-8 83.0-15 83.0-16
ATIACHMENT 3.d CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No. DPR-20 TS Bases Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-8 B 3.0-17 B 3.0-18
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCO LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the plant is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, otherwise e-""~"'"1'*,~n The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
- a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits.
If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the plant in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)
Palisades Nuclear Plant B 3.0-1 Revised 07/26/2017
LCO Applicability B 3.0 BASES LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
- a. An associated Required Action and Completion Time is not met and no other Condition applies; or
- b. The condition of the plant is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the plant. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the plant in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enterfeaBR- lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the plant, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Primary Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
Palisades Nuclear Plant B 3.0-3 Revised 07/26/2017
LCO Applicability 8 3.0 BASES LCO 3.0.3 A plant shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:
- a. The LCO is now met.
is no be. A Condition exists for which the Required Actions have now been performed.
Gd. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in MODE 5 when a shutdown is required during MODE 1 operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for feaffientering the next lower MODE applies. If a lower MODE is reachentered in less time than allowed, however, the total allowable time to feaffientering MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reachentered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reachentering MODE 4 is the next 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br />, because the total time for reachentering MODE 4 is not reduced from the allowable limit of 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to feaffienter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the plant is already in the most restrictive Condition required by LCO 3.0.3.
The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances where requiring a plant shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the plant.
An example of this is in LCO 3.7.14, "Spent Fuel Pool Water Level."
Palisades Nuclear Plant B 3.0-4 Revised 07/26/2017
LCO Applicability B 3.0 BASES LCO 3.0.3 LCO 3.7.14 has an Applicability of "During movement of irradiated fuel (continued) assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the plant in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the plant in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when plant conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered intopermit continued operation in the MODE or other specified condition in the Applicability or for an unlimited period of time. Compliance with ACTIONSRequired Actions that permit continued operation of the plant 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 plant before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made and the m LCO 3.0.4.b allows entry into a MODE or other specified condition 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 CFR50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for 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.
Palisades Nuclear Plant B 3.0-5 Revised 07/26/2017
LCO Applicability B 3.0 BASES LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls 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 required testing to 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 required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply '.vith Required Actions and must be reopened to perform the required testing.
An example of demonstrating the OPERABILITY of other equipment areIB taking an inoperable channel or trip system out of the tripped condition;
- 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system-:-, or A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.
Palisades Nuclear Plant B 3.0-8 Revised 07/26/2017
SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the reliability that (continued) results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs.
The exceptions to SR 3.0.2 are those Surveillances for which the 25%
extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. Examples of where SR 3.0.2 does not apply are the Containment Leak Rate Testing Program required by 10 CFR 50, Appendix J, and the American Society of Mechanical Engineers (ASME) Code inservice testing required by 10 CFR 50.55a. These programs establish testing requirements and frequencies in accordance with the requirements of regulations. The TS cannot, in and of themselves, extend a test interval specified in the regulations directly or by reference.
As stated in SR 3.0.2, the 25% extension allowed by SR 3.0.2 may be applied to Required Actions whose Completion Time is stated as "once per ... " however, the 25% extension does not apply to the initial performance of a Required Action with a periodic Completion Time that requires performance on a "once per ... " basis. The 25% extension applies to each performance of the Required Action after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
Palisades Nuclear Plant B 3.0-17 Amendment No. 262 Revised 07/26/2017
SR Applicability B 3.0 BASES SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performedcompleted within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
When a Section 5.5, "Programs and Manuals," specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 specification).
This delay period provides an adequate time to performcomplete Surveillances that have been missed. This delay period permits the performancecompletion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performancecompletion of the Surveillance.
The basis for this delay period includes consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a 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 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.
However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedlyas an operational convenience to extend Surveillance intervals.
Palisades Nuclear Plant B 3.0-18 Amendment No. 262 Revised 07/26/2017
Insert 1 (TS Bases LCO 3.0.4, page B 3.0-5)
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 in 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.
Insert 2 (TS Bases LCO 3.0.5, page B 3.0-8)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Primary Coolant System (PCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Insert 3 (TS Bases LCO 3.0.5, page B 3.0-8)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 4 (TS Bases LCO 3.0.5, page B 3.0-8)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
Insert 5 (TS Bases SR 3.0.3, page B 3.0-18)
SR 3.0.3 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a
relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
ATTACHMENT 3.e CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Unit 1 TS Bases Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-7 B 3.0-12 B 3.0-13
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements ~
applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entere . The Required Actions establish those remedial measures t ust be taken within specified Completion Times when the r irements of an LCO are not met. This Specification establish at:
- a. etion of the Required Actions within the specified Completion
, unless oth imes constitutes compliance with a Specification; and specified
- b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the
( continued)
RIVER BEND B 3.0-1 Revision No. 1 LCO Applicability B 3.0 BASES (continued)
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
- a. An associated Required Action and Completion Time is not met and no other Condition applies; or
- b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare fo an orderly shutdown before initiating a change in unit operation. is includes time to permit the operator to coordinate the reduction in ectrical generation with the load dispatcher to ensure the stability a availability of the electrical grid. The time limits specified tO-feaefi ower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
(continued)
RIVER BEND B 3.0-3 Revision No/
LCO Applicability B 3.0 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:
- b. The LCO is no longer a. The LCO is now m~---....J pplicable, A Condition exists for which the Required Actions have now been performe,9-4 ~
ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited. entering The time limits o Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a hutdown is required during MODE 1 operation. If the entered unit is in a lower ODE of operation when a shutdown is required, the time limit for
- the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to
--~i:eaeA-MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 i in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reaching MO 1s the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for r@achin@ ODE 3 1s not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore,
- re dial measures are completed that would permit a return to MODE 1, en lty is not incurred by having to a lower MODE of operation in les tha the total time allowed. ,..........___..___,
In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.6, "Fuel Pool Water Level." LCO 3.7.6 has an Applicability of "During movement of irradiated fuel (continued)
RIVER BEND B 3.0-4 Revision No.Y
LCO Applicability 8 3.0 BASES LCO 3.0.3 assemblies in the associated fuel storage pool." Therefore, this LCO can (continued) be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.6 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.6 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met,
~ - r____, LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be lowing entry ent * * *
- the MODE or other specified condition in the Applicabili for an unlimited period of time. Compliance w* ReCluired Actions at permit continued operation of the unit for an ACTIONS unlimited period 1me in a MODE or other specified condition provides an accept level of safety for continued operation. This is without regar the status of the unit before or after the MODE change.
will permit continued erefore, in such cases, entry into a MODE or other specified condition operation within the MODE in the Applicability may be made . ~9Sf>f4.3-Rf~M*~~-BFA¥ +~R.s-~~
.u*
or other specified condition. Req1::1ired Actions.
LCO 3.0.4.b allows entry into a M DE or other specified condition in the Applicability with the LCO not met fter performance of a risk assessment Insert 1 addressing inoperable systems an components, consideration of the (as new paragraph) results, determination of the applica ility of entering the MODE or other specified condition in the Applicabilit , and establishment of risk management actions, if appropriate.
(continued) and the Required Actions followed after entry into the Applicability.
RIVER BEND 8 3.0-5 Revision N o . ~
Insert 1 (TS Bases LCO 3.0.4, page B 3.0-5)
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 in 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.
LCO Applicability B 3.0 BASES LCO 3.0.5 The administrative controls ensure the time the equipment is returned to (continued) service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification Insert 2 not provide time to perform any other preventive or corrective maintenan .
An example of demonstrating the OPERABILITY of the cquipfficflt beiAg returr,eeJ to sen,iee is reopening a co1 ,tai1 ,111e1 ,t isolatio11 valve ti ,al I ,as been closed to comply with Required /\etions, and must be reopened to
~ p e r f o r m tAe SRs.
An cxaffiple of eJemonst1 ati1 ,g the OPERABILITY of other equipment jg' taking an inoperable channel or trip system out of the tripped condition prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other eq* 1ipment is taking an Insert 4 (new inoperable channel or trip system out of the tripped condition to permit the paragraph) --.___ ~ogic to function and indicate the appropriate response during~
~erformance of an SR on another channel in the same trip syst~~-.0- -
LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.
When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The (continued)
RIVER BEND B 3.0-7 Revision No)Y
Insert 2 (TS Bases LCO 3.0.5, page B 3.0-7)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Insert 3 (TS Bases LCO 3.0.5, page B 3.0-7)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 4 (TS Bases LCO 3.0.5, page B 3.0-7)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the reliability that (continued) results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Therefore, when a test interval is specified in the regulations, the test interval cannot be extended by the TS, and the SR include a Note in the Frequency stating, "SR 3.0.2 is not applicable." An example of an exception when the test interval is not specified in the regulations is the Note in the Primary Containment Leakage Rate Testing Program, "SR 3.0.2 is not applicable." This exception is provided because the program already includes extension of test intervals."
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per. .. " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or p to the limit of the specified Frequency, whichever is greater, pplies from the point in time that it is discovered that the Surveillance as not been Y
(continued) performed RIVER BEND B 3.0-12 Revision No. 408-
SR Applicability B 3.0 BASES SR 3.0.3 (continued) performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. This delay period is available provided the initial surveillance has been satisfactorily performed (Ref. NRC Task Interface Agreement TIA 2008-004). This delay period permits the i
..eeiFRB~eR-of a Surveillance before complying with Required Actions or other remedial measures that might of the Surveillanc performance The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a 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 10CFR 50 Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE Insert 5 (new changes imposed by Required Actions. ----
repeatedly paragraph) ---~>
Failure to comply with specified Frequencies for SRs i xpected to be an infrequent occurrence. Use of the delay period est ished by SR 3.0.3 is a flexibility which is not intended to be used as an operational oom:cnicRee to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the 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 or personnel, and the time required to perform the Surveillance. This risk impact should be managed through RIVER BEND B 3.0-13 Revision No. 4e4-
Insert 5 (TS Bases SR 3.0.3, page B 3.0-13)
SR 3.0.3 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR 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 equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
ATTACHMENT 3.f CNR0-2019-00003 Markup of Technical Specification (TS) Bases Pages FOR INFORMATION ONLY Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Unit 3 TS Bases Pages B 3/4 0-2 B 3/4 0-3 B 3/4 0-4 B 3/4 0-5 B 3/4 0-6
Insert 4 (TS Bases, Specification 4.0.3, page B 3/4 0-6)
Surveillance Requirement 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 ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of Surveillance Requirement 4.0.3 would be a relay contact that was not tested as required in accordance with a particular Surveillance Requirement, but previous successful performances of the Surveillance Requirement included the relay contact; the adjacent, physically connected relay contacts were tested during the Surveillance Requirement performance; the subject relay contact has been tested by another Surveillance Requirement; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment 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 performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high 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.
BASES equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.
Specification 3.0.2 establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) 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.
Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.
The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stabilit an availability of the electrical grid. The time limits specified to wer MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.
If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition of Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.
WATERFORD - UNIT 3 B 3/4 0-2 AMENDMENT NO.jef
entering BASES enter Therefore, if remedial measures are complete would permit a return to POWER operation, a penalty is not incurred by having t 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 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.
Specification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance with these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.
WATERFORD - UNIT 3 B 3/4 0-3 AMENDMENT NO.jef'
BASES When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.
Specification 3.0.5 establishes the allowance for restoring equipment to service under administrative controls 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 Specification 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of Surveillance Requirements to 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 urned to service in conflict with the requirements of the ACTIONS is limited to the ti absolutely necessary to perform the allowed Surveillance Requirements. This Speci
- ation does not provide time to perform any other preventive or corrective maintenance.
/\n example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply 'Nith Required Actions and must be reopened to perform the Surveillance Requirements.
nsert 2 An example of demonstrating the OPERABILITY of other equipment* aking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of a Surveillance Requirement on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of a Surveillance Requirement on another channel in the same trip system.
-+EC-15515, Ch. 60)
Specification 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36, and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the ACTIONS entered in accordance with LCO 3.0.2.
+-(EC-15515, Ch. 60)
AMENDMENT NO. 62,99, 101, WATERFORD - UNIT 3 B 3/4 0-4 Changed by letter dated August 22, 1990 CHANGE N0-:-30, Insert 1 (TS Bases, Specification 3.0.5, page B 3/4 0-4)
LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Insert 2 (TS Bases, Specification 3.0.5, page B 3/4 0-4)
Examples of demonstrating equipment OPERABILITY 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 Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY 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 (TS Bases, Specification 3.0.5, page B 3/4 0-4)
The administrative controls in LCO 3.0.5 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 realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
BASES
Some examples of this process are:
- a. Emergency feedwater (EFW) pump turbine maintenance during refueling that requires testing at steam pressures > 750 psig. However, if other appropriate testing is satisfactorily completed, the EFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
- b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI 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 activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as-a-convcnicnoc 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 recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
This extension allowed by Specification 4.0.2 is also applicable to Surveillance Requirements required in Technical specification Actions. However, the extension does not apply to the initial performance. The extension only applies to each performance after the initial performance. The initial performance required by the Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single completion time. One reason for not allowing the extension to this completion time is that such an action usually verifies that no loss of function has occurred or accomplishes the function of the inoperable equipment in an alternative manner.
Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within its specified interval. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the sp 'fied surveillance interval, whichever is greater, applies from the point in time that it is discov red that the Surveillance has not been performed in accordance with Specification 4.0.2, and no at the time that the specified interval was not met.
- (DRN 03-524) perform AMENDMENT NO. 99 WATERFORD - UNIT 3 B 3/4 0-5 CHANGE NO.
BASES
This delay period provides an adequate time to Surveillances that have been missed. This delay period permits t of a Surveillance before complying with required actions or o e ial measures that might rec of the Surveillance.
performance r 1s delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with an interval based not on time intervals, but upon specified unit conditions, operational 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, Specification 4.0.3 allows for the full delay period of up to the specified interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required actions. repeat Insert 4 Failure to comply with specified intervals for surveillance requirem is expected to be an infrequent occurrence. Use of the delay period established by R
- 1cation 4.0.3 is a flexibility which is not intended to be used *
- o extend Surveillance intervals.
While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified interval 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 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at 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 Surveillances 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's Corrective Action Program.
AMENDMENT NO. 99, WATERFORD - UNIT 3 B 3/4 0-6 CHANGE N0.-2-3-