ML20137C678

Proposed Tech Specs Rev Re LCO 3.0.3,Key Licensing Issue 19 Deleting Exemption for Entry

ML20137C678
Person / Time
Site:	05200003
Issue date:	03/19/1997
From:	WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20137C676	List: ML20137C678 NSD-NRC-97-5030, Submits Revised Response & Markup of LCOs 3.0.2 & 3.0.3 & Bases for NRC Review.Rev Deletes Exemption for Entry Into LCO 3.0.3
References
NUDOCS 9703250082
Download: ML20137C678 (9)

Text

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LCO Applicability

• 3.0

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3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LC0 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LC0 3.0.2.

LC0 3.0.2 Upon discovery of a failure to meet an LCO, the Required l Actions of the associated Conditions shall be met, except as  !

provided in LC0 3.0.5 or 3.0.6.

In some cases, the Required Actions specify that the unit be shutdown and placed in a lower MODE. When plant conditions or configuration prevent the unit from being brought to the required MODE within the time limits specified using normal plant procedures, expedited actions shall be taken to establish and maintain the required plant conditions. This should be accomplished in a controlled and orderly manner in accordance with normal plant procedures, well within the specified maximum cooldown rate and within the capabilities of the unit using the available plant systems and components.

Ertry 5t: LC0 3.0.3 is r,ct r:;9ed " ti.;; ;ituatic .

If the LC0 is met, or is no longer applicable prior to expiration of the specified Completion Time (s), completion of i the Required Action (s) is not required, unless otherwise ,

l stated. l I

LCO 3.0.3 When an LC0 is not met and the associated ACTIONS are not mety an associated ACTION is not provided, or if directed by the i associated ACTIONS;the unit shall be placed in a MODE or other specified conditi6n in which the LCO is not applicable.

A:. tion shall be initiated within I hour to place the unit, as applicable, in:

a. MODE 3 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; and

b. MODE 4 within hours; and

c. MODE 5 within g , g5g g g y When plant conditions or configuration prevent the unit from being brought to the required MODE within the time limits specified above using normal plant procedures, expedited actions shall be taken to establish and maintain the required plant conditions. This should be accomplished in a controlled (continued) k 9703250082 970319 '

PDR ADOCK 05200003

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h AP600 3.0-1 08/96 Amendment 0 l

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LCO Applicability

, 3.0 3.0 LCO APPLICABILITY LC0 3.0.3 and orderly manner in accordance with normal plant procedures, (continued) $npFL within the specified maximum cooldown rate and within the capabilities of the unit using the available plant systems and components.

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 LC0 3.0.3 is not required. LC0 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LC0 is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Exceptions to this specification are stated in the individual Specifications. These exceptions allow entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered allow unit operation in the MODE or other specified condition only for a limited period of time.

LC0 3.0.4 is only applicable for. entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

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 tbs OPERABILITY of other equipment. This is an exception to LC0 3.0.2 for the system i returned to service under administrative control to perform

the test required to demonstrate OPERABILITY.

(continued)

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(b)AP600 o.oa,o.oon.

3.0-2 08/96 Amendment 0 noi 4

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l LC0 Applicability B 3.0 l l B 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY BASES 1 i

LCOs LC0 3.0.1 through LCO 3.0.6 establish the general  !

requirements applicable to all Specifications and apply at  !

all times, unless otherwise stated. I l

l LC0 3.0.1 LC0 3.0.1 establishes the Applicability statement within l each individual Specification as the requirements for when 1 the LCO is required to be met (i.e. when the unit is in the MODES or other specified conditions of the Applicability l statement of each Specification.) i LC0 3.0.2 LC0 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 the ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LC0 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 LC0 is met within the specified Completion Time, unless otherwise specified.

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c. Required Actions which specify unit shutdown require the use of nonsafety related systems which may be unavailable. C::plien : "4+h

+ha sp::ified C::pletica Tit : is act caeir:d nonsafety system (s) I vely E edpursued kestoration such thatof the the required uni shutdown prectisei.. Eze:r, unit is accomplished conditions  :: :::n shall ahe be:s Whin VW th! d ,

considered by the operators such that overall safety is forrpO optimized. These considerations may include delay of Tire.

repairs or use of temporary equipment. In these cases, Specification compliance is maintained by completion of the specified shutdown.e seca e; ,,c : tic:1. I:

l p-+ 4 c"h , trrritiaa F cr "^0: 3 te (continued)

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h AP600 B 3.0-1 OB/96 Amendment 0 m n o.ot, or..

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LCO Applicability B 3.0 i

BASES LC0 3.0.2 MODE ' u M nnly the naub, ;;fety rel&ted 3p im(d (continued) may be 2cccep'iched 'r, & tirce ;;re:ter thr 2d hour ;. -

Although nonsafety related systems are necessary for RCS cooldown to less than 200*F within the Completion Times specified, OPERABILITY of the nonsafety related systems is not required or implied by these Technical Specifications.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LC0 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 j specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the l Specification is not applicable. (Whether stated as a l Required Action or not, correction of the entered Condition l 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 to the Required Actions provides an acceptable level of safety for continued I operation.  !

Completing the Required Actions is not required when an LC0 l is met, or is no longer applicable, unless otherwise stated in the individual Specifications.,

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is

-the case. An example of this is in LC0 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The 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 1

(continued)

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h AP600 B 3.0-2 08/96 Amendment 0 uo,w aen,osooone

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• LC0 Applicability  ;

B 3.0 l l

BASES 1 LCO 3.0.2 convenience. Alternatives that would not result in (continued) redundant equipment being inoperable should be used instead. Doing so limits the time both subsystems / trains I

' of a safety function are inoperable and limits the time other conditions could exist which result in LC0 3.0.3 being entered. Individual Specifications may specify a l

' time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the i

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

When a change in MODE or other specified condition is  !

required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the ,

Completion Times of the associated Required Actions would I apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition (s) are entered.

I LC0 3.0.3 LC0 3.0.3 establishes the actions that must be implemented when an LC0 is not met; and: i i

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 l

Conditions are such that entering LC0 3.0.3 is warranted; in such cases, the ACTIONS specifically l

state a Condition corresponding to such combinations and also that LC0 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 i 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.

(continued) k h AP600 B 3.0-3 08/96 Amendment 0 APOluettuous\1003 #06480290

i LCO Applicability

,. B 3.0 BASES LC0 3.0.3 Upon entering into LC0 3.0.3, I hour is allowed to prepare (continued) for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit. The specified Completion Times assume the availability of nonsafety related systems that are normally used during a unit cooldown. All or some of these systems will be used, as necessary, to establish and maintain the required MODE. Usingonlythepassig systems, the time to reach MODJ 4 is $e, safety relatedkpectpd 1

specified Completion Time (N%ours) and ts"Yary, depending j upon the specific systems used and the initial and transitory plant conditions experienced during the MODE change. For example, the unit can be brought to MODE 4 in approximately 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> using the Passive Residual Heat Removal System. Regardless of the cooldown systems available, the MODE changes will be completed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the available cooldown systems. 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 LC0 3.0.3 are consistent with the discussion of Section 1.3, " Completion Times".

Although nonsafety related systems ;xh ;; :t:rtup fu i: ter (fer ;tc;; ;=: rite

• helt r;;;sel) and ner;;l re i&:1 h .; rc:"21 ile9 with the :::e;;.ieu support mi;;; are necessary for RCS cooldown to less than 200*F (MODE 5) within the Completion Times specified, OPERABILITY of th: n :r :thec nonsafety related systems is not required i or implied by these Technical Specifications.

If nonsafety related systems required to complete a shutdown in accordance with LC0 3.0.3 are not available, Q# the systems shall be restored as needed to accomplish the shutdownl System restoration shall be completed as soon as

@Y # p . possible; however, unit conditions shall also be considered

c, by the operators such that overall safety is optimized.

These considerations may include delay of repairs or use of temporary equipment.

k h AP600 B 3.0-4 08/96 Amendment 0 mw o.mm.m.

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LC0 Applicability

. B 3.0 BASES <

l LC0 3.0.3. A unit shutdown required in accordance with LC0 3.0.3 may (continued) be terminated, and LC0 3.0.3 exited if any of the following occurs: j 1

l a. The LC0 is now met. I

b. A Condition exists for which the Required Actions have l now been performed.

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c. ACTIONS exist that do not have expired Com)letion l Times. These Completion Times are applica)le from the point in time that the Condition was initially entered l

' and not from the time LC0 3.0.3 is exited.

7 clop Ob8 h m .)

l The time limits of Specification 3.0.3 allow 'S hr: for l the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a lower MODE is reached in less time than allowed, however, the total allowable time to reach MODE 5, or other applicable MODE is i not r. educed. For example, if MODE 3 is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, i

then the time allowed for reaching MODE 5 is the next RG 4F hours, because the total time for reag MODE 5 is not reduced from the allowable limit of AA U. - Therefore, if remedial measures are completed that woul permit a l 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.

1 In MODES 1, 2, 3, and 4 LCO 3.0.3 provides actions for i Conditions not covered in other Specifications. The J requirements of LC0 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 l LC0 3.0.3 do not apply in other specified conditions of the Applicability unless in MODES 1, 2, 3, or 4) because the ACTIONS of ind vidual Specifications sufficiently define the remedial measures to be taken.

Examples of the required end states specified for inoperable passive systems while in MODES 5 and 6 are provided in Table B 3.0-1, Passive Systems Shutdown MODE

, Matrix. These requirements are specified in the individual l Specifications. The required end states specified for passive systems, when the unit is in MODE 5 or 6, are

! selected to ensure that the initial conditions and system and equipment availabilities minimize the likelihood and consequences of potential shutdown events.

(continued) h AP600 B 3.0-5 08/96 Amendment 0

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LC0 Applicability

• B 3.0 h n l

a Table B 3.0-1 (page 1 of 1) l Passive Systems Shutdown MODE Matrix-l LCO Automatic Applicability Depressureuon Core Makeup Pauive RHR 1RWST Containment containment System Tank .

Cooling MODE 5 9 of 10 pathe One CMT System One injection now Clueurs espebility Two water flow RCS OPERABLE OPERABLE CPERABLE path and one paths prenure All paths closed recirculation sump OPERABLE boundary flow path closed OPERABLE I

LCO 3.4.13 LCO 3.5.3 LC O 3.5.5 LCO 3.5.7 LCO 3.6.8 LCO 3.6.7 MODES MODES MODES MODES MODES MODES Required RCS pressure RCS prusure RCS pressure RCS pressure RCS pressure . RCS pressure End State boundary open, boundary open, boundary open, boundary closed, boundary closed, boundary closed, visible level in visible level in visible level in visible level in visible level in visible level in pressuriser pressurizer pressuriser pressurizar pressurizar pressunser MODE 5 Stega I,2, and 3 None None One injection flow closure capability Two water flow RCS open path and one paths prusure . 2 s age 4 velva recirculation sump OPERABLE boundary ' OPERABLE flow path open OPERABLE LCO 3.4.14 LCO 3.5.7 LCO 3.6.8 LCO 3.6.7 Required MODE 5 MODE 5 MODE 5 MODE 5 End State RCS prosauro RCS pressure RCS presure RCS pressure boundary open, boundary closed, boundary closed, boundary closed, visible levelin visible levelin visible levelin visible levelin pressurizar pressunser pressuriser pressunser MODE 5 Stages I,2, and 3 None None One injection flow Closure capability Two water oow RCS open path and one paths premure 2 stage 4 valves recirculation surmy OPERABLE boundary OPERABLE flow path open, OPERABLE reduced RCS inventory LCO 3.4.14 - LCO 3.5.8 LCO 3.6.8 LCO 3.6.7 Required MODE 5 MODE 5 MODE 5 MODE 5-End State RCS pressure RCS pressure RCS pressure RCS pressure -

boundary apen, boundary closed, boundary closed, boundary closed, visible levelin visible levelin visible level in visible levelin prosauriser pressuriser pressuriser pressunzer MODE 6 Stages I,2, and 3 None None One irjaction flow Closure capabihty Two water flow Reactor open path and one paths internals in 2 stage 4 valves recirculation sump OPERABLE place, OPERABLE flow path refueling OPERABLE cavity not full LCO 3.4.14 LCO 3.5.8 LCO 3.6.8 LCO 3.6.7 Required MODE 6 MODE 6 MODE 6 MODE 6 End State n.-.,- isaarnale Resciar haarnals Reactor internale Reactor internels removed, ' removed, refueling removed, refueling removed. l reAnaling envity - cavity full cavity full refueling cavity l full ' full MODE 6 None None None None Closure capability None Reactor internels removed, refueling j- cavity full Lf0 3.6.8 l I Required MODE 6 l End State Reactor internale l removed, renseling caviey A u i

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@ AP600 e n.e anieu o m e m B 3.0-6 08/96 Amendment 0 l l

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LC0 Applicability 1

.,. B 3.0 l

BASES i

LCO 3.0.3 Exceptions to 3.0.3 are provided in instances where (continued) requiring a unit shutdown in accordance with LC0 3.0.3, would not provide appropriate remedial measures for the i

associated condition of the unit. An example of this is in i LC0 3.7.5, Spent Fuel Pool Water Level. This Specification has an Applicability of "At all times." Therefore, this ,

, LCO can be applicable in any or all MODES. If the LCO and  !

the Required Actions of LC0 3.7.5 are not met while in i

MODES 1, 2, or 3, there is no safety benefit to be gained I by placing the unit in a shutdown condition. The Required J. Action of LCO 3.7.5 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 LC0 l 3.0.3. These exceptions are addressed in the individual l Specifications. i 1

LC0 3.0.4 LC0 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 MODE or j other specified condition stated that Applicability (e.g., ,

Applicability desired to be entered) when the following j exist:

a. Unit conditions are such that the requirements of the LC0 would not be met in the Applicability desired to be entered; and l i

b. Continued noncompliance with.the LC0 requirements, if )

the Applicability were entered, would result in the '

unit being required to exit the Applicability desired to be entered to comply with the Required Actions.

Compliance with Required 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 in accordance with the provisions of the Required Actions.

(continued)

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b AP600 B 3.0-7 08/96 Amendment 0

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