ML20217F096

Proposed Tech Specs Pages,Incorporating New Spec 3.0.5 Administrative Controls,Currently Approved for Use in NUREG-1431

ML20217F096
Person / Time
Site:	Seabrook
Issue date:	03/23/1998
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20217F083	List: ML20217F077 ML20217F093 ML20217F096
References
RTR-NUREG-1431 NUDOCS 9803310277
Download: ML20217F096 (12)

Text

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting' Conditions As peooc:.(p for Operation,A W 5Peu rtterso 3.o.5",the associated ACTION requirements shall be metpcE 3.0.2 Noncompliance with a specification shall exist when the requirements of the Lim'iting Condition for Operation and associated ACTION requirements are not met within the specified time intervalsj If the Limiting Condition for Operation completion is ofrestored the ACTION priorrequirements to expirationisofnot therequireo.

specified time intervals,

'esceer m (censo M g ecurscArM 3. o. 5 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. 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 />,

b. 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

c. 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.

This specification is not applicable in MODE 5 or 6.

3.0.4 Entry.into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condi-tion may be made in accordance with ACTION requirements when conformance to '

them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual specifications.

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9803310277 980323 l PDR ADOCK 05000443 P PDR SEABROOK - UNIT 1 3/4 0-1 38F d~

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. -. h/4.0 APPLfCABILITY

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BASES i

3: Therefore, if. remedial measures are completed that would permit a retiern to F POWER operation,.a penalty is not incurred by having to reach a lower MODE of I' operation in less than the total time allowed.

, The same principle applies with regard to the allowable' outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one-specification results in entry into'a MODE or condition of operation for-another specification in which the requirements of the Limiting Condition Nr Operation.are not met.. If the new specification becomes applicable in less time than-specified, the difference.may be added to the allowable outage time limits of-the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 do not apply in MODES 5 and 6, because the ACTION requirements of individual specifications define the remedial measures to be taken.

Specification 3.0.4 establishes limitations on MODE changes when a Limiting Concition for Operation is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant-before or after a MODE change. Therefore, in this case, entry into an OPERATIONAL MODE'or other specified condition may be made in accordance with the' provisions of the ACTION requirements. The provisions of this~ specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup. I When a. shutdown is required to comply with ACTION requirements, the provisions

- of. Speci.fication 3.0.4 do not apply because they would delay placing the p facility in a lower MODE of operation. ,

pecifications 4.0.1 through'4.0.5 establish f.he general requirements appl.icable to Surveillance. Requirements. These requirements are based on the i Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c)(3):

" Surveillance requirements are requirements relating to test,

,' calibration, or inspection' to ensure that the necessary quality of systems and  !

components,is' maintained? that. facility operation will be within safety climitJ. and'that the-limiting conditions of operation will be met."

LSEABR00K1--UNIT.1. B $4!0-3 q JcQM h r

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INSERT .

. A.;

3.0.Si Equipment removed from service or declared inoperable to comply with ' ACTIONS;may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to Specifications 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform thei testing required .

to demonstrate OPERABILITYr INSERT' B:

c Specincation 3.0.5 establishes the allowance for restoring equipment to service under administrative

-controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to Specifications 3.0.1 and 3.0.2 (e.g., to not comply with the applicable Required Action (s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

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

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 required testing 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 required testing on another channel in the same trip system.

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i SECTION III Retype of Proposed Changes The attached retype reflects the currently issued version of the Technical Specifications. Pending

-Technical Speelfication changes or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.

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I 3/4 LIMITING' CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITI'NG CONDITION FOR OPERATION

- 3. 0.1l 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. except as provided in Specification 3.0.5. I

'3.0 2 Noncompliance with a specification shall exist when the-requirements of the Limiting Condition for Operation and associated ACTION c

requirements are not met within the specified time intervals, except as:

provided in Specification 3.0.5. If tie Limiting Condition for Operation!is

' restored arior to exp1_ ration of the.specified time intervals, completion of the ACTIO4 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 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. 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 />,

b. 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

c. 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 accerdance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 Entry into an OPERATIONAL MODE or another specified condition ,

shall not be made when the conditions for the Limiting Conditions for Operation are not met and the ' associated ACTION requires a shutdown if they

.are not met within a specified time interval. Entry into an OPERATIONAL MODE i or specified condition may be made in accordance with ACTION requirements when

.conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to 0PERATIONAL MODES as required to comply with ACTION recuirements.

Exceptions ~to these requirements are stated in the indivicual specifications.

t3.0.5 Equi: ment removed from service or declared inoperable to comply with

. ACTIONS.may )e 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 Specifications 3.0.1 and 3.0. 2 for the system. returned to service under administrative control to perform the 1 testing required to demonstrate OPERABILITY,

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SEABROOKL-0 NIT-1 3/4 0-1 Amendment j i

. ,3/4.0 APPLICABILITY BASES Therefore, if remedial measures are completed that would permit a return to POWER operation, a 3enalty is not incurred by having to reach a lower MODE of operation in less tlan the total time allowed.

The same 3rinciple applies with regard to the allowable outage time limits of the ACTIO1 requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less time than s)ecified, the difference may be added to the allowable outage time limits of t1e second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

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

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

Soecification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this s)ecification is to ensure that facility operation is not initiated or that ligher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in this case.

entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the 3rovisions of the ACTION requirements. The provisions of this specification slould not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.

Soecification 3.0.5 establishes the allowance for restoring ecuipment to service under administrative controls when it has been removec from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to Specifications 3.0.1 and 3.0.2 (e.g,.. to not comply with the applicable Required Action (s)) to allow the performance of required testing to demonstrate:

'SEABROOK - UNIT 1 B 3/4 0-3 Amendment

.- 3/4.0 APPLICABILITY BASES

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 required testing. 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 M reopened to perform the required testing.

An. exam)le of demonstrating the OPERABILITY of other equipment is taking an inoperaale channel or trip system out of the tripped condition to prevent the

. trip function from occurring during the performance of required testing 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 required testing on another channel in the same trip system.

Soecifications 4.0.1 throuah 4.0.5 establish the general requirements applicable to Surveillance Requirements. These recuirements are based on the Surveillance Requirements stated in the Code of Feceral Regulations 10 CFR 50.36(c)(3):

" Surveillance requirements are requirements relating to test.

calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

SEABROOK - UNIT 1 B 3/4 0-3A Amendment-

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I Section IV Determination of Significant flazards for Proposed Changes 1

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IV. DETERMINATION OF SIGNIFICANT IIAZARDS FOR PROPOSED CIIANGES License Amendment Request (L.AR) 98-10 proposes an administrative change to the Seabrook Station Technical Specifications (TS) to incorporate the administrative controls of new Specification 3.0.5, currently approved for use in NUREG-1431," Standard Technical Specifications - Westinghouse Plants,"

(as modified by approved Technical Specification Task Force (TSTF) generic change Traveler TSTF-165), to provide an exception to Specifications 3.0.1 and 3.0.2 to allow the performance of required testing to demonstrate the operability of the equipment being returned to service or the operability of other equipment, in accordance with 10 CFR 50.92, North Atlantic has reviewed the attached proposed changes and has concluded that they do not involve a significant hazards consideration (SIIC). The basis for the conclusion that the proposed changes do not involve a SilC is as follows:

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The design basis accidents are not affected by the proposed administrative changes.

Specification 3.0.5 provides the administrative controls to ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absohitely necessary to perform the allowed required testing. Specification 3.0.5 was incorporated in NUREG-1431, " Standard Technical Specifications - Westinghouse Plants," (as modified by approved Technical Specification Task Force (TSTF) generic change Traveler TSTF-165), to address these, and other similar situations, that conflict with the requirements ]

with the ACTIONS when equipment is returned to service. Specification 3.0.5 does not provide i time to perform other preventative or corrective maintenance. l l

Inclusion of Specification 3.0.5 into the Seabrook Station Technical Specifications will provide operational flexibility with the restrictive compliance requirements of the other Applicability i Specifications (3.0.1 and 3.0.2) and allow the performance of post-maintenance / surveillance activities to facilitate returning equipment to service or to allow other equipment to be tested.

Therefore, inclusion of Specification 3.0.5 into the Seabrook Station Technical Specifications enhances plant safety by minimizing the potential for plant trip and/or transients. A qualitative risk assessment concerning returning components to service for post-maintenance testing was performed and concluded that the configurations allowed by Specification 3.0.5 have a negligible effect on the Seabrook Station risk profile. The components involved will have either completed calibration or maintenance, and can reasonably be expected to be able to perform their required safety function when returned to service for testing purposes. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed.

The proposed changes do not introduce new features or modify plant structures, systems and components or procedures that could possibly affect station operations under normal or abnormal conditions, thus, the potential for an unanalyzed accident is not created. The proposed Page 7

3 administrative changes have no adverse affect on the safety limits or design basis accidents.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed. l l

3. The proposed changes do not involve a significan't reduction in a margin of safety.

There are no changes being made to the Technical Specification safety limits or safety system .

settings that would adversely affect plant safety. The changes do not affect the operation of structures, systems or components (SSCs) nor do they introduce administrative changes to plant l procedures that could affect operator response during normal, abnormal or emergency situations. {

Inclusion of Specification 3.0.5 into the Seabrook Station Technical Specifications enhances j plant safety by minimizing the potential for plant trip and/or transients by allowing equipment to ]

be returned to service. A qualitative risk assessment concerning the return of components to )

service for post-maintenance testing was performed and concluded that the configurations i allowed by Specification 3.0.5 have a negligible effect on the Seabrook Station risk profile. The {

components involved will have either completed calibration or maintenance, and can reasonably I be expected to be able to perform their required safety function when returned to service for )

testing purposes. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, North Atlantic concludes that the proposed changes do not constitute a significant hazard.

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v 4 Sections V & VI Proposed Schedule for License Amendment Issuance and Effectiveness and EnvironmentalImpact Assessment Page 9

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V. PROPOSED SCHEDULE FOR. LICENSE AMENDMENT ISSUANCE AND EFFECTIVENESS-North Atlantic requests NRC review of License Amendment Request 98-10 and issuance of a license

- amendment by May 15,1998, having immediate effectiveness and implementation required within 60 days.

VI. . ENVIRONMENTAL IMPACT ASSESSMENI North Atlantic has reviewed the proposed license amendment against the criteria of 10 CFR 51.22 for-environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluent that may be released offsite, nor significantly increase

' individual or cumulative occupational radiation exposures. Based on the foregoing, North Atlantic

. concludes that the proposed changes meets the criteria delineated in 10 CFR St.22(c)(9) and 10 CFR 51.22 (c)(10) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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