ML20211K120

Proposed Tech Specs,Adding New Specification That Addresses Use of Interim Provisions Upon Discovery of Unintended TS Action

ML20211K120
Person / Time
Site:	Sequoyah
Issue date:	08/30/1999
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20211K124	List: ML20211K120
References
NUDOCS 9909070109
Download: ML20211K120 (27)

Text

-

ENCLOSURE 2 l

TENNESSEE VALLEY AUTHORITY l

SEQUOYAH PLANT (SQN) l UNITS 1 AND 2 l

l PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE MARKED PAGES 1

l I.

AFFECTED PAGE LIST Unit 1 Index Page II 1-7 l

3/4 0-1 l

B 3/4 0-3 Unit 2 Index Page II 1-7 l

1-8 3/4 0-1 B 3/4 0-3 II.

MARKED PAGES See attached.

9909070109 990030 PDR ADOCK 05000327 p

PDR i

l E2-1

6 c

INDEX

, DEFINITIONS SECTIQN PAGE 1.0 DEFINITIONS (Continued) 1.24 PURGE - PURGING 1-5 1.25 QUADRANT POWER TILT RATIO 1-5 1.26 RATED THERMAL POWER (RTP) 1-5 1.27 REACTOR TRIP SYSTEM RESPONSE TIME 1-5 1.28 REPORTABLE EVENT 1-5 1.29 SHIELD BUILDING INTEGRITY.

1-6 1-6 1.30 SHUTDOWN MARGIN.

1.31 SITE BOUNDARY.

1-6 1.32 SOLIDIFICATION 1-6 1.33 SOURCE CHECK 1-6 R159 1.34 STAGGERED TEST BASIS 1-6 1

l i

1.35 THERMAL POWER 1-6 J6wUNIDENTIFIED-LEAKAGE---mw.

/. J 7 U/VIAAWO@ TEC//N/fAfL S

/ CAT /0AJ //C7~/OA) T. v. -l.

-7 v-J-7

.W.

.%- r.^

.7~NM.TM'177 1J'f,g'ONRtSTRIDTEDM$A.

I 1 38g ITILATION EXHAUST TREATMENT SYSTEM 1-7 1 35g VENTING 1-7 RATIONAL MODES (TABLE 1.1) 1-8 R75 FREQUENCY NOTATION (TABLE 1.2) 1-9 October 23, 1991 SEQUOYAH - UNIT 1 II Amendment No. 71, 155

4

[7&s if2eres /Armc7ED By 75C 78-/O UNIDENTIFIED LEAKAGE

.1.36 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE R159 r FahPPD AT.T.En T.Phlf hf2P

/

4 &WCKr 1)

YSThI NED AREA 3

1 An UNRESTRICTED AREA shall be any area, at or beyond the site boundary to lR159 Ich access is not controlled by the licensee for purposes of protection of 1

individuals from exposure to radiation and radioactive materials or any area R75 within the site boundary used for residential quarters or industrial, commerical, institutional, and/or recreational purposes.

VENTILATION EXHAUST TREATMENT SYSTEM

' 39 1

A VENTILATION. EXHAUST TREATMENT SYSTEM is any system designed and lR159 natalled to reduce. gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or parti-culates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).

Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 96 1.

VENTING is the controlled process of discharging air or gas from a lR159 onfinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING.

Vent, used in system names, does not imply a VENTING process.

l I

SEQUOYAH - UNIT 1 1-7 Amendment No. 12, 71, 155 October 23, 1991

'3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS

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

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

If the Limiting Cond4tions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

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

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.

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

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

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the Andividual Specifications.

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely

-because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of ito applicable Limiting condition for Operation, provided:

(1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s),

train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both conditions (1) and (2) are l

satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE

'in.which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.

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

This Specification is not applicable in MODES 5 or 6.

3.0.6 Equipment removed from service or declared inoperable to comply with R206 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 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

AV

=

-Xmr 2 June 13, 1995 SEQUOYAH - UNIT 1 3/4 0-1 Amendment No. 202

APPLICABILITY BASES instead, provided the other specified conditions are satisfied.

In this case,

'this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service R206 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 LCOs 3.0.1 and 3.0.2 (e.g.,

to not comply with the applicable Required Action [s]) to allow the performance of SRs to demonstrater 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 perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service isireopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to 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 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 h

C:^4.0.1 a specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions'for which the Limiting conditions for Operation are applicable.

Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual Specification.

l June 13, 1995 SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78, 162, 202 i

i

e 1.0 DEFINITIONS (Continued) 1.24 PURGE - PURGING 1-5 1.25 QUADRANT POWER TILT RATIO 1-5 1.26. ' RATED THERMAL POWER. (RTP) 1-6 1.27 REACTOR TRIP SYSTEM RESPONSE TIME 1-6 1.28 REPORTABLE EVENT 16 1.29 ' SHIELD BUILDING INTEGRITY 1-6 1.30 SHUTDOWN MARGIN-16 1.31 ' SITE BOUNDARY.

1-6 R146

'1.32 SOLIDIFICATION' 1-7 1.33: SOURCE CHECK 1-7 1.34 STAGGERED TEST BASIS 1-7 1.35. THERMAL POWER.

1-7 i h~1MKJBvWgsas,yerion.. e.....

-7

1. g,

_._ m..............

m..

m

'1.3 ILATION EXHAUST TREATMENT SYSTEM 1-8 1.34 NTING 1-8 OPERATIONAL MODES (TABLE 1.1) 19 j

R63 FREQUENCY NOTATION (TABLE.1.2) 1 10 March 30, 1992 SEQUOYAH UNIT 2 II Amendment No. 63, 146 J

g_..

p.

~

l-DEFINITIONS-i l

. SOLIDIFICATION-l-

[

1.32 Deleted, R146 SOURCE CHECK 1.33' Deleted.

R146 STAGGERED TEST BASIS

'1.34 A STAGGERED TEST BASIS shall consist of lR146 a.

A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals, b.

The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

THERMAL POWER 1.35 THERMAL POWER shall be the total reactor core heat transfer rate to the lR146 reactor coolant.

UNIDENTIFIED LEAKAGE l'.36 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE lR146

%QJ_C.,O p L p GE.

V' IJSENT b h n AREA

{*1.

UNRESTRICTED AREA shall be any area, at or beyond the site boundary to lR146 access is not. controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area R63

-within the site boundary used for residential quarters or industrial, commer-cial,-institutional, and/or recreational purposes.

l March 30, 1992

'SEQUOYAH -' UNIT 2 1-7 Amendmemt Nos. 63, 134, 146 1

I

I l

l l

DEFINITIONS l

. VENTILATION EXHAUST TREATMENT SYSTEM 1"

A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and lR146 l

n talled to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal l

adsorbers and/or HEPA filters for the purpose of removing iodines or partic-ulates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).

l Engineered Safety Feature (ESP) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING H

VENTING is the controlled process of discharging air or gas from a lR146 con inement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not l

provided or required during VENTING.

Vent, used in system names, does not imply a VENTING process.

l l

l J

l l

l March 30, 1992 SEQUOYAH - UNIT 2 1-8 Amendment Nos. 63, 146 l

l

p

~

+

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS J/4.0 APPLICABILITY

+

LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications 10 required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

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

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

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it as a licable, in AtleastbbTSTANDBYwkthinthenext6 hours, 1.

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.

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

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

Exceptions to these requirements are stated in the individual Specifications.

'3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION requirements.

Exceptions to these requirements are stated in the individual Specifications.

l 3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting condition for Operation, provided:

(1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s),

train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the i

requirements of this Specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 2.

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

]

3.

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

This Specification is not applicable in MODES 5 or 6.

3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to R192 perform testing required to demonstrate its OPERABILITY or the OPEPABILITY of other equipment..This is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

1 rn--

MEW 2.

June 13, 1995 SEQUOYAH - UNIT 2 3/4 0-1 Amendment No. 192

BASES

3. 0. 5. (Continued) specified conditions are satisfied.

In this case, this would mean that for one division the emergency power source must be OPERABLE ( as must be the components supplied by the emergency power' source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If_these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3.0.6 LCO 3.0.6: establishes the allowance for restoring equipment to service R192 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 LCOs 3.0.1 and 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 l-service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs.

This Specifhation does not provide time to perform any other preventive or corrective masntenance.

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 SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to 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 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 h G7w 3 +

W Th13'Bpecification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicab!.e.

Provisions for additional surveil-lance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Require-ments.

Surveillance Requirements for Special Test Exceptions need only be I

performed when the Special Test Exception is being utilized as an exception to I

l an individual. Specification.

i l

i l

l -

l i

i June 13, 1995 SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No. 69, 152, 192

Insert 1 UNINTENDED TECHNICAL SPECIFICATION ACTION 1.37 An UNINTENDED TECHNICAL SPECIFICATION ACTION is an unnecessary plant evolution or other action that results from an erroneous Technical Specification requirement..The erroneous Technical Specification may arise from an editorial error, an administrative error, or a technical inconsistency between a Technical Specification requirement and the underlying intent of the requirement as defined in supporting documents submitted to or. generated by the NRC.

The intended Technical Specification i

requirement, as described in applicable documentation, is not

)

contradicted by'other documentation of which the licensee is aware.

' Insert 2.

1 3.0.7 If a condition is identified that will result in an UNINTENDED TECHNICAL SPECIFICATION ACTION, operation may continue l

and, for an interim period, the licensee will be in compliance L

with the affected Technical Specification provided that a corrected Technical Specification requirement is defined and implemented.

The interim, corrected Technical Specification will comply with the technical intent and underlying purpose of the affected Technical Specification as defined in supporting documents submitted to or generated by the NRC.

If a Technical Specification requirement is modified in accordance with this provision, an application to amend the Technical Specifications to correct the identified discrepancy will be submitted to the NRC within 60 days of the identification of the erroneous l

Technical Specification requirement (i.e.,

the interim, corrected Technical Specification requirement).

The application to correct the Technical Specification discrepancy will present the basis for classifying the condition as an UNINTENDED TECHNICAL SPECIFICATION ACTION.

The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision onLthe proposed correction to the identified error.

I Insert 3.

3.0.7 Compliance with a Technical Specification involves l

compliance with.the technical intent and the underlying purpose L

of the Technical' Specification'.

Compliance is based, in part, on the definitions provided/in'Section 1.0, common definitions of words not defined.in Section 1.0, and the construction of sentences, clauses, and phrases.

The technical intent and underlying purpose is established by the applicable Bases, any associated Safety Evaluations issued by the NRC, the Updated Final Safety Analysis Report, or other documentation generated by

.either the licensee or the NRC.

,4.s l Insert 3 ~ (continued)

Experience has demonstrated that there are cases in which an

• iss6ed Technical Specification may literally be inconsistent with the' technical intent and underlying purpose of the specification.

The inconsistency may.not be discovered until the resulting compliance would force, for example, an unnecessary plant evolution or unnecessarily restrict plant operations.

The normal regulatory processes such as Notices of Enforcement Discretion and amendment of-the Technical. Specifications using emergency or exigent provisions are an ineffective way of' dealing with these circumstances, given that the discrepancies associated with the use of this' specification do not present a safety concern.

The low significance of these discrepancies may be readily concluded since'the intent of the affected Technical Specification requirement'is supported by existing docketed information.

As such,; prior NRC consent for an interim, corrected Technical Specification requirement to address an UNINTENDED TECHNICAL SPECIFICATION ACTION is'not warranted.

To correct the UNINTENDED TECHNICAL SPECIFICATION ACTION and to

. inform the NRC of the' actions taken, an application for a license amendment will be submitted to the NRC whenever this provision is exercised.

The application for a license amendment will be submitted to the NRC within 60 days of the identification of an erroneous requirement that causes an UNINTENDED TECHNICAL SPECIFICATION ACTION and a decision to implement an interim,

-corrected Technica1' Specification in place of the erroneous

-requirement. _The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision on the

' licensee's. proposed correction to the identified error.

In cases where the erroneous requirement involves a repetitive 1

surveillance or condition, the requirement to submit an

. application to amend the Technical Specifications will satisfy subsequent occurrences until the NRC issues a decision pertaining to the amendment request.

It is important that thia-provision not be perceived as anything

.other than a mechanism to resolve discrepancies that are occasionally introduced into Technical Specification requirements.

The use of this provision is limited to the erroneous-types of requirements previously discussed.

The use of the UNINTENDED TECHNICAL SPECIFICATION ACTION provision is not an alternative to a Notice of Enforcement Discretion or Technical Specification amendments in accordance with 10 CFR 50.90 and 50.91 when the subject Technical Specification requirement is not clearly in error.

Improper use of this provision, either by classifying a condition as an UNINTENDED TECHNICAL SPECIFICATION ACTION when the_ requirement'was not in error or by the failure to implement an appropriate interim, corrected requirement, constitutes a violation of the Technical Specification at issue as well as this Technical Specification.

l' ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE REVISED PAGES I.

AFFECTED PAGE LIST Unit 1 Index Page II j

1-7 3/4 0-la B 3/4 0-3 B 3/4 0-3a B 3/4 0-4 Unit 2 Index Page II 1 1-8 3/4 0-la B 3/4 0-3 B 3/4 0-3a

)

B 3/4 0-4 II.

REVISED PAGES

)

See attached.

)

E3-1

.y..

INDEX

. DEFINITIONS' SECTION.

PAGE 1.0 DEFINITIONS (Continued) 1.24 PURGE - PURGING-.

1-5 1.25. QUADRANT POWER TILT. RATIO.

1-5

'ATED THERMAL POWER (RTP) 1.26 R

1-5 1.27 REACTOR TRIP SYSTEM RESPONSE TIME 1-5 1.28 ' REPORTABLE EVENT 1-5 1.29 SHIELD BUILDING INTEGRITY.

1-6 1.30 SHUTDOWN MARGIN.

1-6 1.31 SITE BOUNDARY.

1-6

-1.32

' SOLIDIFICATION 1-6 1.33 SOURCE CHECK 1-6 R159 1.34 STAGGERED TEST BASIS 1-6 1.35L THERMAL POWER.-.

1-6 1.36' UNIDENTIFIED LEAKAGE 1-7 1.37 UNINTENDED TECHNICAL SPECIFICATION ACTION.

1-7 1.38 UNRESTRICTED AREA.

1-7 1.39 VENTILATION EXHAUST TREATMENT SYSTEM 1-7 1.40 VENTING 1-7 OPERATIONAL MODES (TABLE 1.1) 1-8 R75 FREQUENCY NOTATION (TABLE 1.2) 1-9' SEQUOYAH - UNIT 1 II Amendment No. 71, 155,

/

s UNIDENTIFIED LEAKAGE

• 1.36

• UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE lR159 or CONTROLLED LEAKAGE.

UNINTENDED TECHNICAL SPECIFICATION ACTION 1.37 An UNINTENDED TECHNICAL SPECIFICATION ACTION is an unnecessary plant evolution or other action that results from an erroneous Technical Specification requirement. The erroneous Technical Specification may arise from an editorial error, an administrative error, or a technical inconsistency between a Technical Specification requirement and the underlying intent of the requirement as defined in supporting documents submitted to or generated by the NRC.

The intended Technical Specification requirement, as described in applicable documentation, is not contradicted by other documentation of which the licensee is aware.

UNRESTRICTED AREA 1.38 An UNRESTRICTED AREA shall be any area, at or beyond the site boundary to l

which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area R75 within the site boundary used for residential quarters or industrial, commerical, institutional, and/or recreational purposes.

VENTILATION EXHAUST TREATMENT SYSTEM 1.39 A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and l

installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or parti-culates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).

4 Engineered Safety Feature (ESP) atmospheric cleanup systems are not considered j

to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 1.40 VENTING is the controlled process of discharging air or gas from a l

confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. _ Vent, used in system names, does not imply a VENTING process.

SEQUOYAH - UNIT 1 1-7 Amendment No. 12, 71, 155,

,. /

l APPLICABILITY I

LIMITING CONDITION FOR OPERATION 3.0.7 If a condition is identified that will result in an UNINTENDED TECHNICAL SPECIFICATION ACTION, operation may continue and, for an interim period, the licensee will be in compliance with the affected Technical Specification

.provided that a corrected Technical Specification requirement is defined and implemented.

The interim, corrected Technical Specification will comply with the technical intent and underlying purpose of the affected Technical Specification as defined in supporting documents submitted to or generated by the NRC.

If a Technical Specification requirement is modified in accordance with this provision, an application to amend the Technical Specifications to correct the identified discrepancy will be submitted to the NRC within 60 days of the identification of the erroneous Technical Specification requirement (i.e., the interim, corrected Technical Specification requirement). The applicatien to correct the Technical Specification discrepancy will present the basis for classifying the condition as an UNINTENDED TECHNICAL SPECIFICATION ACTION. The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision on the proposed correction to the identified error.

i SEQUOYAH - UNIT 1 3/4 0-1a Amendment No.

I

.s*

l,s l

l APPLICABILITY BASES instead, provided the other specified conditions are satisfied.

In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service R206 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 LCOs 3.0.1 and 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 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 with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to 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 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.

3.0.7 Compliance with a Technical Specification involves compliance with the technical intent and the underlying purpose of the Technical Specification.

Compliance is based, in part, on the definitions provided in Section 1.0, common definitions of words not defined in Section 1.0, and the construction of sentences, clauses, and phrases. The technical intent and underlying purpose is established by the applicable Bases, any associated Safety Evaluations issued by the NRC, the Updated Final Safety Analysis Report, or other documentation generated by either the licensee or the NRC.

Experience has demonstrated that there are cases in which an issued Technical Specification may literally be inconsistent with the technical intent and underlying purpose of the specification.

The inconsistency may not be discovered until the resulting compliance would force, for example, an unnecessary plant evolution or unnecessarily restrict plant operations. The normal regulatory process such as Notices of Enforcement Discretion and amendment of the Technical Specifications using emergency or exigent provisions are an ineffective way of dealing with these circumstances, given that the discrepancies associated with the use of this specification do not present a safety concern.

The low significance of these discrepancies may be readily concluded since the intent of the affected Technical Specification requirement is supported by existing docketed information. As such, prior NRC consent for an interim, corrected Technical Specification requirement to address an UNINTENDED TECHNICAL SPECIFICATION ACTION is not warranted.

SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78, 162, 202,

,e i

APPLICABILITY BASES

.To correct the UNINTENDED TECHNICAL SPECIFICATION ACTION and to inform the NRC of the actions taken, an application for a license amendment will be submitted to the NRC whenever this provision is exercised.

The application for a license amendment will be submitted to the NRC within 60 days of the identification of j

an erroneous requirement-that causes an UNINTENDED TECHNICAL SPECIFICATION s

ACTION and a decision to implement an interim, corrected Technical specification in place of the erroneous requirement. The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision on the licensee's proposed correction to the identified error.

In cases where the erroneous requirement involves a repetitive surveillance or condition, the requirement to submit an application to amend the Technical Specifications will satisfy subsequent occurrences until the NRC issues a decision pertaining to the amendment request.

It is important that this provision not be perceived as anything other than a

. mechanism to resolve discrepancies that are occasionally introduced into Technical Specification requirements. The use of this provision is limited to the erroneous types of requirements previously discussed. The use of the UNINTENDED TECHNICAL SPECIFICATION ACTION provision is not an alternative to a Notice of Enforcement Discretion or Technical Specification amendments in accordance with 10 CFR 50.90 and 50.91 when the subject Technical Specification requirement is not clearly in error.

Improper use of this provision, either by classifying a condition as an UNINTENDED TECHNICAL SPECIFICATION ACTION when the requirement was not in error or by failure to implement an appropriate interim, corrected requirement, constitutes a violation of the Technical Specification at issue as well as this Technical Specification.

4.0.1 This specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements. Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual Specification.

l 4.0.2 Specification 4.0.2 established 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 e 7 ducting the surveillance; e.g.,

transient conditions or other ongoing surveillan.e or maintenance activities.

It also provides

' flexibility to accomodate the length of a fuel cycle for surveillances that are R166 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 convenience 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 judgement and the recognition that the most probalbe 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.

SEQUOYAH - UNIT 1 B 3/4 0-3a Amendmnet No. 78, 162, 202, L_.

,..i I

APPLICABILIIY

. BASES 4.0.3 This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provit ions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.

Under the provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are l

found or known to be inoperable although still meetlag the Surveillance Requirements.

This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance l

interval was exceeded.

Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3.

However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation r

I that is subject to enforcement action.

Further, the failure to perform a surveillance within the provisions of Specification 4.0.2 is a violation of a R82 Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73 (a) (2) (1) (B) because it is a condition prohibited by the plant's Technical Specifications.

If the allowable outage time limits of the ACTION requirement are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (the allowable outage time limits are defined as the first timeframe encountered in the ACTION requirement) or a shutdown is required to comply with ACTION requirements, e.g.,

Specification 3.0.3, a 24-hour allowance is provided l

to permit a delay in implementing the ACTION requirements.

This provides an I

adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed.

If a surveillance is not completed wie'in the 24-hour allowance, the time limits of the ACTION requirements are op, y 'e at that time.

When a l

surveillance is performed within the 24-hour alt ace and the Surveillance Requirements are not met, the time limits of the AtrION requirements are applicable at the time that the surveillance is terminated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Requirements have to be met to demonstrate that l

inoperable equipment has been restored to OPERABLE status.

1 August 15, 1988 SEQUOYAH - UNIT 1 B 3/4 0-4 Amendment No. 78 1

e 1.0 DEFINITIONS (Continued) i 1.24 PURGE - PURGING 1-5 1.25 QUADRANT POWER TILT RATIO 1-5 1.26 RATED THERMAL POWER (RTP) 1-6 1

1.27 REACTOR TRIP SYSTEM RESPONSE TIME.

1-6 1.28 REPORTABLE EVENT 1-6 i

1.29 SHIELD BUILDING INTEGRITY 1-6 1.30 SHUTDOWN MARGIN 1-6 1.31 SITE BOUNDARY.

1-6 R146 1.32 SOLIDIFICATION 1-7 1.33 SOURCE CHECK 1-7 1.34 STAGGERED TEST BASIS 1-7 1.35 THERMAL POWER 1-7 1.36 UNIDENTIFIED LEAKAGE 1-7 1.37 UNINTENDED TECHNICAL SPECIFICATION ACTION.

1-7 1.38 UNRESTRICTED AREA.

1-7 1.39 VENTILATION EXHAUST TREATMENT SYSTEM 1-8 1.40' VENTING 1-8 OPERATIONAL MODES (TABLE 1.1) 1-9 R63 FREQUENCY NOTATION (TABLE 1.2) 1-10 l

SEQUOYAH - UNIT 2 II Amendment No. 63, 146,

DEFINITIONS

. SOLIDIFICATION 1.32 Deleted.

R146 SOURCE CHECK 1.33 Deleted.

R146 STAGGERED TEST BASIS 1.34 A STAGGERED TEST BASIS shall consist of:

lR146 a.

A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals, b.

The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.

THERMAL POWER 1.35 THERMAL POWER shall be the total reactor core heat transfer rate to the lR146 i

reactor coolant.

UNIDENTIFIED LEAKAGE 1.36 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE lR146 or CONTROLLED LEAKAGE.

UNINTENDED TECHNICAL SPECIFICATION ACTION i

1.37 An UNINTENDED TECHNICAL SPECIFICATION ACTION is an unnecessary plant

]

evolution or other action that results from an erroneous Technical Specification requirement. The erroneous Technical Specification may arise j

from an editorial error, an administrative error, or a technical inconsistency between a Technical Specification requirement and the underlying intent of the requirement as defined in supporting documents submitted to or generated by the NRC.

The intended Technical Specification requirement, as described in applicable documentation, is not contradicted by other documentation of which the licensee is aware.

i j

UNRESTRICTED AREA 1.38 An UNRESTRICTED' AREA shall be any area, at or beyond the site boundary to l

which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area R63 within the site boundary used for residential quarters or industrial, commer-cial, institutional, and/or recreational purposes.

)

I i

SEQUOYAH - UNIT 2 1-7 Amendmemt Nos. 63, 134, 146,

h 6

.. ' o g

DEFINITIONS

. VENTILATION EXHAUST TREATMENT SYSTEM 1.39-A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and l

installed to reduce gaseous radiciodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or partic-ulates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).

Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 1.40 VENTING is the controlled process of discharging air or gas from a l

confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTisu. Vent, used in system names, does not imply a VENTING process.

)

1 1

I I

'SEQUOYAH - UNIT 2 1-8 Amendment Nos. 63, 146,

F' L

[s..'

l APPLICABILITY l

l LIMITING CONDITION FOR OPERATION 3.0.7 If a condition is identified that will result in an UNINTENDED TECHNICAL SPECIFICATION ACTION, operation may continue and, for an interim period, the licensee will be in compliance with the affected Technical Specification provided that a corrected Technical Specification requirement is defined and implemented. The interim, corrected Technical Specification will comply with the technical intent and underlying purpose of the affected Technical Specification as defined in supporting documents submitted to or generated by l

l the NRC.

If a Technical Specification requirement is modified in accordance with this provision, an application to amend the Technical Specifications to correct the identified discrepancy will be submitted to the NRC within 60 days

.of the identification of the erroneous Technical Specification requirement

(

(i.e., the interim, corrected Technical Specification requirement). The application to correct the Technical Specification discrepancy will present the basis for classifying the condition as an UNINTENDED TECHNICAL SPECIFICATION i

ACTION. The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision on the proposed correction to the identified error.

l l

t SEQUOYAH - UNIT 2 3/4 0-la Amendment No.

i

T j.e BASES specified conditions are satisfied.

In this case, this would mean that for one division the emergency power source must be OPERABLE ( as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these j

MODES must be adhered to.

3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to service R192 under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

The sole purpose of this Specification is I

to provide an exception to LCOs 3.0.1 and 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 i

b.

The OPERABILITY of other equipment.

1 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 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 with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to 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 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.

3.0.7 Compliance with a Technical Specification involves compliance with the technical intent and the underlying purpose of the Technical Specification.

Compliance is based, in part, on the definitions provided in Section 1.0, common definitions of words not defined in Section 1.0, and the construction of sentences, clauses, and phrases. The technical intent and underlying purpose is established by the applicable Bases, any associated Safety Evaluations issued by the NRC, the Updated Final Safety Analysis Report, or other documentation generated by either the licensee or the NRC.

Experience has demonstrated that there are cases in which an issued Technical Specification may literally be inconsistent with the technical intent and underlying purpose of the specification.

The inconsistency may not be discovered until the resulting compliance would force, for example, an unnecessary plant evolution or unnecessarily restrict plant operations. The normal regulatory process such as Notices of Enforcement Discretion and amendment of the Technical Specifications using emergency or exigent provisions are an ineffective way of dealing with these circumstances, given that the discrepancies associated with the use of this specification do not present a safety concern. The low significance of these discrepancies may be readily concluded since the intent of the affected Technical Specification requirement is supported by existing docketed information. As such, prior NRC consent for an interim, corrected Technical Specification requirement to address an UNINTENDED TECHNICAL SPECIFICATION ACTION is not warranted.

SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No. 69, 152, 192,

4 es APPLICABILITY BASES To correct the UNINTENDED TECHNICAL SPECIFICATION ACTION and to inform the NRC of the actions taken, an application for a license amendment will be submitted to.the NRC whenever this provision is exercised.

The application for a license amendment will be submitted to the NRC within 60 days of the identification of an erroneous requirement that causes an UNINTENDED TECHNICAL SPECIFICATION ACTION and a decision to implement an interim, corrected Technical specification in place of the erroneous requirement. The licensee may use the interim, corrected Technical Specification requirement to comply with the affected Technical Specification until the NRC issues a decision on the licensee's proposed correction to the identified error.

In cases where the erroneous requirement involves a repetitive surveillance or condition, the requirement to submit an application to amend the Technical Specifications will satisfy subsequent occurrences until the NRC issues a decision pertaining to the amendment request.

It is important that this provision not be perceived as anything other than a mechanism to resolve discrepancies that are occasionally introduced into Technical Specification requirements. The use of this provision is limited to the erroneous types of requirements previously discussed.

The use of the UNINTENDED TECHNICAL SPECIFICATION ACTION provision is not an alternative to a Notice of Enforcement Discretion or Technical Specification amendments in accordance with 10 CFR 50.90 and 50.91 when the subject Technical Specification requirement is not clearly in error.

Improper use of this provision, either by classifying a condition as an UNINTENDED TECHNICAL SPECIFICATION ACTION when the requirement was not in error or by failure to implement an appropriate interim, corrected requirement, constitutes a violation of the Technical Specification at issue as well as this Technical Specification.

4.0.1 This specification provides that surveillance activities necessary to I

insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveil-lance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Require-ments.

Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual Specification.

4.0.2 Specification 4.0.2 established 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 accomodate the length of a fuel cycle for surveillances that are R152 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 convenience 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 judgement and the recognition that the most probalbe 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.

SEQUOYAH - UNIT 2 B 3/4 0-3a Amendment Nos. 69, 152, 192,

t

• 4..

3 BASES 4.0.3 This specification establishes the failure to perform a surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the provisions of this specification, systems and components are assumed to be OPERABLE when' Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded.

Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3.

However, this does not negate R69 the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action.

Further, the failure to perform a surveillance within the provisions of Specification 4.0.2 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73 (a) (2) (i) (B) because it is a condition prohibited by the plant's Technical Specifications.

If the allowable outage time limits of the ACTION requirement are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (the allowable outage time limits are defined as the first timeframe encountered in the ACTION requirement) or a shutdown is required to comply with ACTION requirements, e.g.,

Specification 3.0.3, a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance.

This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance Requirements that are I

applicable when an exception to the requirements of Specification 4.0.4 is allowed.

If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time.

When a surveillance is performed within the 24-hour allowance and the Serveillance Requirements are not met, the time limits of the ACTION requiremer.ts are applicable at the time that the surveillance is terminated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

August 15, 1988 SEQUOYAH - UNIT 2 B 3/4 0-4 Amendment No. 69