ML20036B794

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SSAR Markup of TS B3.0 Re LCOs
ML20036B794
Person / Time
Site: 05200001
Issue date: 05/24/1993
From:
GENERAL ELECTRIC CO.
To:
Shared Package
ML20036B793 List:
References
NUDOCS 9306020346
Download: ML20036B794 (14)


Text

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i LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

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LCOs LCO 3.0.1 through LCO 3.0.7 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LC0 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LC0 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 o

Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions pQ establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification es' $lishes 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 (continued) gBWRkSTS B 3.0-1 O, 05/26/97 9306020346 930524 PDR ADOCK 0520 1

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LCO Applicability B 3.0 e

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LCO 3.0.2 ACTIONS.) The second type of Required Action specifies the (continued) 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 Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required A.ctions 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 3.8.I, "AC Sources-Operating."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, o

perfomance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational

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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 d '...V' "#

convenience. Alternatives that would not result in redundant equipment being inoperable should be d instead.

Doing so limits the time both subsystems /

of a safety function are inoperable and limits the time et er conditions exist which result in LCO 3.0.3 being entered.

Individual Specifications may specify a time limit for perfoming an SR when equipment is removed from service or bypassed for testing.

In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in HODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition (s) are entereds (continued)

ABWR/gSTS B 3.0-2 Rn.

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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:

An associated Required Action and Completion Time is a.

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 irmnediately.

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 7

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intended to be used as an operational convenience that O

pemits 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, I hour is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to pemit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure _the stability and availability of the electrical grid.

The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces themal. 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)

O A BWR N STS B 3.0-3

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LCO Applicability B 3.0 i

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 1

occurs:

a.

The LCO is now met.

i b.

A Condition exists for which the Required Actions have now been perfomed.

c.

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

l 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 during MODE 1 operation.

If the unit is in a lower MODE of operation when a shutdown is required, the time limit for i

reaching the next lower MODE applies.

If a lower MODE is reached in less time than allowed, however, the total allowable time to reach MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is reached 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 MODE 3 is the next O

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 reaching MODE 3 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 reach a lower MODE of operation in less than 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 i

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 i

LCO 3.7.1, " Fuel Pool Water Level." LCO 3.7.

has an Applica lity of "During movement of irradiate fuel S

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(continued) j h BWRhi STS B 3.0-4 t/.

O. 09/2B/02-l' 1

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LCO Applicability B 3.0 BASES 6

'6 LCO 3.0.3 assemblies in the asso ted fuel sto ge pool." Therefore, (continued) this LCO can be appli able in any or all MODES.

If the LCO and the Required Ac ons of LCO 3.7... are not met while in MODE 1, 2, or 3, tr re is no safety benefit to be gained by placing the unit i a shutdown condition.

The Required Action of LCO 3.7.

of " Suspend mover,ent 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 LC0 is not met.

It precludes placing the unit in a different MODE or other specified condition when the following exist:

The requirements of an LCO, in the MODE or other a.

specified condition to be entered, are not met; and b.

Continued noncompliance with these LCO requirements would result in the unit being required to be placed in a MODE or other specified condition in which the LCO does not apply to comply with the Required Actions.

Complionce with Required Actions that pemit 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 in accordance with 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 unit startup.

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 (continued)

O d BWRhi STS B 3.0-5 6.

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LCO Applicability B 3.0

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LCO 3.0.4 or other specified conditions in the Applicability that (continued) result from a nomal shutdown.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

Surveillances do not have to be perfomed on the associated inoperable equipment (or on variables outside the specified limits), as pemitted by SR 3.0.1.

Therefore, changing MODES or other specified conditions while in an ACTIONS Condition, either in compliance with LCO 3.0.4, or where an exception to LCO 3.0.4 is stated, is not a violation of SR 3.0.1 or SR 3.0.4 for those Surveillances that do not have to be performed due to the associated 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.

g LCO 3.0.5 (J

LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been T

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 SRs 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 allowed SRs. This Specification does not provide time to perfom any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment (continued)

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@BWRhi STS B 3.0-6 Jn.

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LCO Applicability B 3.0 BASES LC0 3.0.5 isolation valve that has been closed to comply with Requirec (continued)

Acti sWl nd must be reopened to perfom the SRs.

A ex mp e of demonstrating the OPERABILITY of he ipment is taking an ineperable channel or trip out of the tripped condition to prevent the trip st lon 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 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 an SR 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 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 Os 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.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported syctem(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 er.sure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be (continued)

O h BWRhk STS B 3.0-7 h.

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LCO Applicability B 3.0 BASES LCO 3.0.6 declared inoperable or direct entry into Conditions and (continued)

Required Actions for the supported system.

This may occur immediately or after some specified delay to perfom some other Required Action. Regardless of whether it is immediate or after some delay, 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.

x Specificationb.

" Safety Function Determination Program" (SFDP), ensures oss of safety function is detected and appropriate actions are taken. Upon failure to meet two or more LCOs concurrently, an evaluation shall be made to detemine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

O Cross division checks to identify a loss of safety function for those support systems that support safety systems are required. The cross division check verifies that the supported systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained.

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

1 LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

J These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions. Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.

Unless otherwise specified, all the other TS requirements remain unchanged. This will i

fBWRMSTS B 3.0-8 h.

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LCO Applicability B 3.0 s

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BASES LCO 3.0.7 ensure all appropriate requirements of the MODE or other (continued) specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the nonnal requirements of the TS. Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements.

If it is desired to perfonn the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of

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the other LCO are not required to be met, unless specified in the Special Operations LCO.

If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.

t lO

@BWRASTS B 3.0-9 Rev.

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SR Applicability y

B 3.0 O-i B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY i

i BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements' 6

applicable to all Specifications and apply at all times, unless otherwise stated.

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SR 3.0.1 SR 3.0.1 establishes the requirement that SRs-must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This-Specification is to ensure that Surveillances are perfomed to verify the OPERABILITY of systems and components, and that variables are within specified limits.

Failure to meet i

a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

i Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this 1

Specification, however, is to be construed as implying.that i

systems or components are OPERABLE when:

P The systems or components are known to be inoperable, a.

although still meeting the SRs; or b.

The requirements of the Surveillance (s) are known to be not met between required Surveillance perfomances.

Surveillances do not have to be perfomed when the unit is in a MODE or other specified condition for which the requirements of the associated'LCO are not applicable, i

unless otherwise specified. The;SRs' associated with a l

Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Surveillances, including Surveillances invoked by Required ~

Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.

.i Surveillances have to be met and performed in accordance-l with SR 3.0.2, prior to returning equipment to OPERABLE status.

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'(continued) h BWRh STS B 3.0-10 k..

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SR Applicability B 3.0 BASES SR 3.0.1 Upon completion of maintenance, appropriate post maintenance (continued) testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent perfomance is in accordance with SR 3.0.2.

Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established.

In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of perfoming its function. This will allow operation to proceed to a MODE or other specified condition where other i

necessary post maintenance tests can be completed. Some examples of this process are:

Control rod drive maintenance during refueling that a.

requires scram testing at > 800 psi. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.3.4 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach 800 psi to perfom other necessary testing.

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High pressure core w{ Loom (HPC$) maintenance du b.

shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPChconsidered OPERABLE.

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

F SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..."

interval.

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 (continued)

O h BWRM STS B 3.0-11 Pr.

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SR Applicability B 3.0 BASES O

SR 3.0.2 (e.g., transient conditions or other ongoing Surveillance or (continued) maintenance activities).

The 25% extension does not significantly degrade the reliability that results from perfoming 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 confomance 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. 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 by approved exemptions." 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."

As stated in SR 3.0.2, the 25% extension also does not apply I

to the initial portion of a periodic Completion Time that requires perfomance on a "once per..." basis.

The 25%

extension applies to each performance after the initial 1

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 or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring i

affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay (continued) d BWRhi. STS B 3.0-12 Re.

O, 09/20/92

SR Applicability

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B 3.0 BASES SR 3.0.3 period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> applies from the point in time that (continued) it is discovered that the Surveillance has not been perfomed in accordance with SR 3.9.2, and not at the time that the specified Frequency was not met. This delay period provides adequate time to complete Surveillances that have been missed.

This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perfom the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable resalt of any particular Surveillance being perfomed is the verification of conformance with the requirements.

When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions or operational situations, is discovered not to have been perfomed when i

specified, SR 3.0.3 allows the full delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perfom the Surveillance.

SR 3.0.3 also provides a time limit for completion 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 as an operational convenience to extend Surveillance intervals.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable then is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period.

If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LC0 (continued) lO bBWRhk STS B 3.0-13 Rev.

O, 09/20/92 i

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SR Applicability i

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B 3.0 i

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SR 3.0.3 Conditions begin immediately upon the failure of the (continued)

Surveillance.

l Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time

.j of the ACTIONS, restores compliance with SR 3.0.1.

t SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified-condition in the Applicability.

i This Specification f.asures that system and evaponent OPERABILITY requirements and variable limits are met before i

entry into MODES or other snecified conditions in the Applicability for which these systems and components ensure safe operation of the unit. This Specification applies to j

changes in MODES or other specified conditions in the a

Applicability associated with unit shutdown as well as i

startup.

f The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability l

that are required to comply with ACTIONS.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not 3

necessary. The specific time frames and conditions necessary for meeting the SRs ara specified in the-Frequency, in the Surveillance, or both. This allows perfomance of Surveillances when the prerequisite condition (s) specified in a Surveillance procedure require l

entry into the MODE or other specified condition in the -

Applicability of the associated LCO prior to the perfomance or completion of a Surveillance. A Surveillance that could-not be perfomed until after entering the LCO Applicability would have its Frequency specified such that it is not "due" j

until the specific conditions needed are met. Alternately,

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the Surveillance may be stated in the.fom of a Note as not required (to be met or performed) until a particular event, J

condition, or time has been reached.. Further discussion of the specific femats of SRs' annotation is found in Section 1.4, Frequency.

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fBWR$STS B 3.0-14 O, 09/26/92

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