ML20302A219

TSTF-562-T, Bases Clarification for TS 3.8.1, Required Actions B.3.1 and B.3.2

ML20302A219
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/27/2020
From:	Office of Nuclear Reactor Regulation
To:	Technical Specifications Task Force
Honcharik,M., NRR/DSS, 301-4151774
Shared Package
ML20302A210	List: ML20302A217 ML20302A218 ML20302A219 ML20302A220 ML20302A221
References
Download: ML20302A219 (14)

Text

TSTF-562-T, Rev. 0 WOG-222, Rev. 0 NUREGs Affected:

Bases Clarification for TS 3.8.1, Required Actions B.3.1 and B.3.2 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement:

Improvement Note: This "T" Traveler has been reviewed and approved by the Technical Specification Task Force and is made available as a template for plant-specific license amendments. This Traveler has not been reviewed and approved by the Nuclear Regulatory Commission.

NRC Fee Status:

Changes Marked on ISTS Rev: 4.0 2194 See attached.

Revision History Affected Technical Specifications OG Revision 0 Revision Status: Active Original Issue Revision

Description:

Revision Proposed by:

PWROG Owners Group Review Information Date Originated by OG:

21-Jul-16 Owners Group Comments:

BWROG and PWROG Licensing Committee members directed that second change be removed.

Date: 10-Aug-16 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

12-Oct-16 Date Distributed for Review: 12-Oct-16 TSTF Comments:

(No Comments)

Date: 15-Nov-16 TSTF Resolution:

Approved for Use Action 3.8.1.B Bases AC Sources - Operating 16-Nov-16 Copyright(C) 2016, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-562, Rev. 0 1

1.

SUMMARY

DESCRIPTION The proper application of Technical Specification (TS) 3.8.1, "AC Sources Operating," Required Action B.3.1, "Determine OPERABLE [diesel generator] DG(s) is not inoperable due to common cause failure," has been a source of inconsistent application. The proposed change modifies the Bases of TS 3.8.1, Action B.3.1 and B.3.2, to clarify the proper application of the common cause failure evaluation required by the TS.

2. DETAILED DESCRIPTION 2.1.

Current Requirements The Bases of TS 3.8.1, Action B.3.1 and B.3.2, state:

Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

2.2.

Reason for the Proposed Change TS 3.8.1, Required Action B.3, applies when a DG is inoperable and requires verification that the redundant, operable DG is not inoperable due to a common cause failure, either by evaluation or by starting the operable DG. A potential point of confusion is the required response when a DG is inoperable for maintenance (corrective or preventive) or testing and a new condition is discovered that could have prevented the DG from being able to performed its specified safety function.

TSTF-562, Rev. 0 2

2.3.

Description of the Proposed Change The Bases of TS 3.8.1, Action B.3.1 and B.3.2, are revised to add a new paragraph:

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

The proposed change is a change to the TS Bases. Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36, states, "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." A licensee may make changes to the TS Bases without prior NRC review and approval in accordance with the Technical Specifications Bases Control Program.

3. TECHNICAL EVALUATION When a DG is declared inoperable, Required Action B.3 requires an operability verification of the remaining DG(s) by either a common cause failure evaluation, B.3.1, or starting the redundant DG(s), B.3.2. While the DG is inoperable, a condition may be discovered that questions whether the inoperable DG could have performed its specified safety function for a reason different from the reason that rendered the DG inoperable. For example, a DG may be inoperable for planned maintenance and an issue with the DG may be discovered which could have prevented the DG from performing its function.

If an LCO is not met, LCO 3.0.2 states the Required Actions of the associated Conditions are to be met. If a DG has been declared inoperable and either Required Action B.3.1 or B.3.2 has been performed, the Required Action is satisfied. There is no TS provision for repeating the performance of an Action when a new issue is discovered on an inoperable component.

Therefore, any new condition discovered affecting an inoperable DG would not be subject to the requirements of Required Action B.3.1 or B.3.2.

An inoperable DG is a condition adverse to quality and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires that "measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." This requirement is acknowledged in the existing TS Bases for Required Actions B.3.1 and B.3.2, which states, "In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. " This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B."

Therefore, should a new condition be discovered affecting an inoperable DG that could have prevented the DG from performing its specified safety function, the evaluation of that new condition is performed under the plant corrective action program, not TS 3.8.1, Action B.

TSTF-562, Rev. 0 3

Conclusion The proposed Bases change is consistent with the TS usage rules and the requirements of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." This change provides the necessary guidance on the performance of a common cause failure evaluation for the identification of subsequent issue on an inoperable DG.

4. REGULATORY EVALUATION A regulatory evaluation is not required for a TS Bases change.

5. REFERENCES None

AC Sources - Operating B 3.8.1 Babcock & Wilcox STS B 3.8.1-7 Rev. 4.0 BASES ACTIONS (continued) emergency feedwater pumps. Single train systems, such as turbine driven emergency feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG.

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

An inoperable DG exists and

b.

A required feature on the other train is inoperable.

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single-failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 Babcock & Wilcox STS B 3.8.1-8 Rev. 4.0 BASES ACTIONS (continued) other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 Westinghouse STS B 3.8.1-7 Rev. 4.0 BASES ACTIONS (continued)

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

An inoperable DG exists and

b.

A required feature on the other train (Train A or Train B) is inoperable.

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is Acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DG(s). If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 Westinghouse STS B 3.8.1-8 Rev. 4.0 BASES ACTIONS (continued)

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 Combustion Engineering STS B 3.8.1-8 Rev. 4.0 4.0, BASES ACTIONS (continued)

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently, is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), the other DG(s) would be declared inoperable upon discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 Combustion Engineering STS B 3.8.1-9 Rev. 4.0 4.0, According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 General Electric BWR/4 STS B 3.8.1-7 Rev. 4.0 BASES ACTIONS (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a.

An inoperable DG exists and

b.

A required feature on the other division (Division 1 or 2) is inoperable.

If, at any time during the existence of this Condition (one DG inoperable),

a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG[s] results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DG(s), they are declared inoperable upon discovery, and Condition E of LCO 3.8.1 is entered. Once the failure is repaired, and the common cause failure no longer exists, Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DGs.

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 General Electric BWR/4 STS B 3.8.1-8 Rev. 4.0 BASES ACTIONS (continued)

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

According to Generic Letter 84-15 (Ref. 7), [24] hours is a reasonable time to confirm that the OPERABLE DGs are not affected by the same problem as the inoperable DG B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two offsite circuits. Required Action C.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed with one division without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are designed with redundant safety related divisions, (i.e., single division systems are not included in the list). Redundant required features failures consist of any of these features that are inoperable because any inoperability is on a division redundant to a division with inoperable offsite circuits.

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 General Electric BWR/6 STS B 3.8.1-7 Rev. 4.0 BASES ACTIONS (continued)

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a.

An inoperable DG exists and

b.

A required feature on another division is inoperable.

If, at any time during the existence of this Condition (one DG inoperable),

a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering one required DG inoperable coincident with one or more required support or supported features, or both, that are associated with the OPERABLE DG(s), results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other DGs, the other DGs are declared inoperable upon discovery, and Condition E of LCO 3.8.1 is entered. Once the failure is repaired, and the common cause failure no longer exists, Required Action B.3.1 is satisfied.

If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those DG(s).

TSTF-562, Rev. 0

AC Sources - Operating B 3.8.1 General Electric BWR/6 STS B 3.8.1-8 Rev. 4.0 BASES ACTIONS (continued)

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed while in Condition B.

If while a DG is inoperable, a new problem with the DG is discovered that would have prevented the DG from performing its specified safety function, a separate entry into Condition B is not required. The new DG problem should be addressed in accordance with the [plant corrective action program].

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable time to confirm that the OPERABLE DG(s) are not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In Condition B, the remaining OPERABLE DGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E distribution system. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1 addresses actions to be taken in the event of concurrent failure of redundant required features. Required Action C.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed with only one division without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These redundant required features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown. These features are designed with redundant safety related divisions (i.e., single division systems are not included in the list, although, for this Required Action, Division 3 is considered redundant to Division 1 and 2 ECCS). Redundant required features failures consist of TSTF-562, Rev. 0