ML20302A221

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TSTF-581-T, Replace References to RG 1.182 with RG 1.160
ML20302A221
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:
References
PWROG-8, Rev 0, TSTF-581-T, Rev 0
Download: ML20302A221 (26)
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Text

PWROG-8, Rev. 0 TSTF-581-T, Rev. 0 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler Replace References to RG 1.182 with RG 1.160 NUREGs Affected: 1430 1431 1432 1433 1434 2194 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.

Classification: 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement: Correction NRC Fee Status:

Benefit: (Unassigned) Changes Marked on ISTS Rev 4.0 PWROG RISD & PA (if applicable): None See attached.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by:

Revision

Description:

Original Issue TSTF Review Information TSTF Received Date: 14-Aug-20 Date Distributed for Review 14-Aug-20 TSTF Comments:

(No Comments)

TSTF Resolution: Approved for Use Date: 31-Aug-20 Affected Technical Specifications SR 3.0.3 Bases LCO Applicability NUREG(s)- 1430 1431 1432 1433 1434 2194 Only LCO 3.0.4 Bases LCO Applicability NUREG(s)- 1430 1431 1432 1433 1434 Only LCO 3.0.9 Bases LCO Applicability NUREG(s)- 1430 1431 1432 1433 1434 Only 01-Sep-20 Copyright(C) 2020, 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-581, Rev. 0

1.

SUMMARY

DESCRIPTION On November 27, 2012, the NRC published a Federal Register Notice (FRN) stating that Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," has been withdrawn and the subject matter had been incorporated into RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.182 is referenced in the Standard Technical Specifications (STS) "LCO Applicability" and "SR Applicability" Bases. The proposed change replaces the references to RG 1.182 with references to RG 1.160.

RG 1.182 and RG 1.160 endorse NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The revisions of RG 1.160 have endorsed different revisions of NUMARC 93-01. The TS Bases contain many Reviewer's Notes that reference a specific revision of NUMARC 93-01. As a global editorial change, the NUMARC 93-01 revision numbers are replaced with the current revision (Revision 4F) and placed in brackets, indicating the appropriate revision number is plant-specific.

2. DETAILED DESCRIPTION 2.1. Current Requirements The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-14321, NUREG-1433 and NUREG-14342, and NUREG-21943.

'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants'." The reference to RG 1.182 was added by TSTF-359-A, Rev. 9, "Increase Flexibility in Mode Restraints."

'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' The 1

NUREG-1430 provides the STS for Babcock & Wilcox plant designs. NUREG-1431 provides the STS for Westinghouse plant designs. NUREG-1432 provides the STS for Combustion Engineering plant designs.

2 NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in some cases, BWR/5 designs. NUREG-1434 provides the STS for the BWR/6 plant design, and is representative, in some cases, of the BWR/5 plant design.

3 NUREG-2194 provides the STS for Westinghouse Advanced Passive (AP) 1000 plant designs.

Page 1

TSTF-581, Rev. 0 reference to RG 1.182 was added by TSTF-427-A, Rev. 2, "Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability."

'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants'."

The reference to RG 1.182 was added by TSTF-358-A, Rev. 6, "Missed Surveillance Requirements."

  • The Bases of many specifications contain a Reviewer's Note that reflects a commitment in the model application of the traveler that added the TS provisions. The Notes are similar to:

Adoption of [the TS provision] requires the licensee to make the following commitments:

1. [Licensee] will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision 3, July 2000.

In addition, the NUREG-1433 and NUREG-1434 TS 3.5.2, "RPV WIC" Bases reference NUMARC 93-01, Revision 4.

2.2. Reason for the Proposed Change The November 27, 2012 FRN stated in part:

The withdrawal of RG 1.182 does not alter any prior or existing licensing commitments based on its use Although [RG 1.182] is withdrawn, current licensees may continue to use it, and withdrawal does not affect any existing licenses or agreements. Withdrawal of

[RG 1.182] means that the guide should not be used for future NRC licensing activities.

[W]ithdrawal of RG 1.182 does not alter the acceptability of the guidance contained in that RG on compliance with 10 CFR 50.65(a)(4), inasmuch as that guidance is now contained in RG 1.160, Revision 3.

As stated in the FRN, RG 1.182 should not be used for future NRC licensing activities.

Therefore, the proposed change replaces the STS references to RG 1.182 with references to RG 1.160.

2.3. Description of the Proposed Change The LCO 3.0.4 Bases are revised (deleted words are struck through, added words are in bold):

The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

Page 2

TSTF-581, Rev. 0 The LCO 3.0.9 Bases are revised:

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65(a)(4), and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.

The SR 3.0.3 Bases are revised:

This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

A global editorial change is made to update all references to a NUMARC 93-01 revision number to "[4F]" and to remove the revision date. This affects the TS Bases shown in Table 1. Because of their number and their editorial nature, markups of each change are not included.

3. TECHNICAL EVALUATION On November 27, 2012, the NRC published an FRN stating that Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," has been withdrawn and the subject matter had been incorporated into RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (77 FR 70846). RG 1.182 and RG 1.160 endorse NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

At the July 10, 2014, TSTF/NRC meeting, the NRC requested that in the future license amendment requests to adopt Travelers that reference RG 1.182, should instead reference RG 1.160. By letter dated September 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14259A575), the TSTF provided the following information: (a) a listing of specific travelers affected by the withdrawal of the RG 1.182, and (b) a description of proposed actions to be taken by licensees and the NRC for future license amendment requests based on these Travelers. An enclosure to the TSTF letter contains specific Travelers by number which include references to RG 1.182 or a previous version of NUMARC 93-01 and proposed certain changes which should be made by licensees adopting these Travelers.

On February 26, 2015, the NRC transmitted a letter to the TSTF titled, "U.S. Nuclear Regulatory Commission Response to the TSTF Letter Regarding References to Regulatory Guide 1.182 in Approved Travelers," (ADAMS Accession No. ML15033A152). The NRC staff found that the TSTFs proposed revisions to risk-informed Travelers is consistent with the November 27, 2012, FRN and concluded that the proposed actions in the TSTFs letter are adequate measures to resolve the issue.

Page 3

TSTF-581, Rev. 0 Of the travelers discussed in the September 16, 2014 TSTF letter, only three inserted references to RG 1.182 into the TS Bases. The proposed change updates those references to RG 1.160 to reflect the current NRC documents.

4. REGULATORY EVALUATION A regulatory evaluation, regulatory analysis, No Significant Hazards Consideration Analysis, and Environmental Evaluation are not required for changes to the TS Bases.
5. REFERENCES None.

Page 4

TSTF-581, Rev. 0 Table 1 STS Bases Affected by Revising NUMARC 93-01 References to Revision "[4F]"

NUREG-1430 3.0.9, "LCO Applicability," Reviewer's Note.

3.6.3, "Containment Isolation Valves," Reviewer's Note 3.9.3, "Containment Penetrations," Reviewer's Note.

NUREG-1431 3.0.9, "LCO Applicability," Reviewer's Note.

3.9.4, "Containment Penetrations," Reviewer's Note.

NUREG-1432 3.0.9, "LCO Applicability," Reviewer's Note 3.3.5, "Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip (Analog)," Reviewer's Note 3.3.9, "Chemical and Volume Control System (CVCS) Isolation Signal (Analog)," Reviewer's Note 3.3.10, "Shield Building Filtration Actuation Signal (SBFAS) (Analog)," Reviewer's Note 3.3.6, "Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip (Digital)," Reviewer's Note 3.3.8, "Containment Purge Isolation Signal (CPIS) (Digital)," Reviewer's Note 3.3.9, "Control Room Isolation Signal (CRIS) (Digital)," Reviewer's Note 3.4.6, "RCS Loops - MODE 4," Reviewer's Note 3.5.4, "Refueling Water Tank (RWT)," Reviewer's Note 3.6.2, "Containment Air Locks," Reviewer's Note 3.6.3, "Containment Isolation Valves," Reviewer's Note 3.6.4A, "Containment Pressure," Reviewer's Note 3.6.4B, "Containment Pressure," Reviewer's Note 3.6.5, "Containment Air Temperature," Reviewer's Note 3.6.6A, "Containment Spray and Cooling Systems," Reviewer's Note Page 5

TSTF-581, Rev. 0 3.6.6B, "Containment Spray and Cooling Systems," Reviewer's Note 3.6.11, "Shield Building (Dual)," Reviewer's Note 3.7.7, "Component Cooling Water (CCW) System," Reviewer's Note 3.7.8, "Service Water System (SWS)," Reviewer's Note 3.7.9, "Ultimate Heat Sink (UHS)," Reviewer's Note 3.7.10, "Essential Chilled Water (ECW) System," Reviewer's Note 3.7.11, "Control Room Emergency Air Cleanup System (CREACS)," Reviewer's Note 3.7.12, "Control Room Emergency Air Temperature Control System (CREATCS)," Reviewer's Note 3.7.13, "Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)," Reviewer's Note 3.7.15, "Penetration Room Exhaust Air Cleanup System (PREACS)," Reviewer's Note 3.8.1, "AC Sources - Operating," Reviewer's Note 3.8.4, "DC Sources - Operating," Reviewer's Note 3.8.7, "Inverters - Operating," Reviewer's Note 3.9.3, "Containment Penetrations," Reviewer's Note.

NUREG-1433 3.0.9, "LCO Applicability," Reviewer's Note 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," Reviewer's Note 3.4.3, "Safety/Relief Valves (S/RVs)," Reviewer's Note 3.5.1, "ECCS - Operating," Reviewer's Note 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control" 3.5.3, "RCIC System," Reviewer's Note 3.6.1.6, "Low-Low Set (LLS) Valves," Reviewer's Note 3.6.1.7, "Reactor Building-to-Suppression Chamber Vacuum Breakers," Reviewer's Note 3.6.1.8, "Suppression Chamber-to-Drywell Vacuum Breakers," Reviewer's Note 3.6.1.9, "Main Steam Isolation Valve (MSIV) Leakage Control System (LCS)," Reviewer's Note 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling," Reviewer's Note 3.6.2.4, "Residual Heat Removal (RHR) Suppression Pool Spray," Reviewer's Note Page 6

TSTF-581, Rev. 0 3.6.4.1, "[Secondary] Containment," Reviewer's Note 3.6.4.3, "Standby Gas Treatment (SGT) System," Reviewer's Note 3.7.1, "Residual Heat Removal Service Water (RHRSW) System," Reviewer's Note 3.7.2, "[Plant Service Water (PSW)] System and [Ultimate Heat Sink [UHS))," Reviewer's Note 3.7.4, "[Main Control Room Environmental Control (MCREC)] System," Reviewer's Note 3.7.5, "[Control Room Air Conditioning (AC)] System," Reviewer's Note 3.7.6, "Main Condenser Offgas," Reviewer's Note 3.8.1, "AC Sources - Operating," Reviewer's Note 3.8.4, "DC Sources - Operating," Reviewer's Note 3.8.7, "Inverters - Operating," Reviewer's Note 3.8.9, "Distribution Systems - Operating," Reviewer's Note NUREG-1434 3.0.9, "LCO Applicability," Reviewer's Note 3.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring," Reviewer's Note 3.4.4, "Safety/Relief Valves (S/RVs)," Reviewer's Note 3.5.1, "ECCS - Operating," Reviewer's Note 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control" 3.5.3, "RCIC System," Reviewer's Note 3.6.1.6, "Low-Low Set (LLS) Valves," Reviewer's Note 3.6.1.7, "Residual Heat Removal (RHR) Containment Spray System," Reviewer's Note 3.6.1.8, "Penetration Valve Leakage Control System (PVLCS)," Reviewer's Note 3.6.1.9, "Main Steam Isolation Valve (MSIV) Leakage Control System (LCS)," Reviewer's Note 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling," Reviewer's Note 3.6.4.1, "[Secondary] Containment," Reviewer's Note 3.6.4.3, "Standby Gas Treatment (SGT) System," Reviewer's Note 3.6.5.6, "Drywell Vacuum Relief System," Reviewer's Note 3.7.1, "[Standby Service Water (SSW)] System and [Ultimate Heat Sink (UHS)]," Reviewer's Note 3.7.3, "[Control Room Fresh Air (CRFA)] System," Reviewer's Note Page 7

TSTF-581, Rev. 0 3.7.4, "[Control Room Air Conditioning (AC)] System," Reviewer's Note 3.7.5, "Main Condenser Offgas," Reviewer's Note 3.8.1, "AC Sources - Operating," Reviewer's Note 3.8.4, "DC Sources - Operating," Reviewer's Note 3.8.7, "Inverters - Operating," Reviewer's Note 3.8.9, "Distribution Systems - Operating," Reviewer's Note NUREG-2194 None Page 8

TSTF-581, Rev. 0 Technical Specifications Bases Markup

TSTF-581, Rev. 0 LCO APPLICABILITY B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

Babcock & Wilcox STS B 3.0-5 Rev. 4.0

TSTF-581, Rev. 0 LCO APPLICABILITY B 3.0 BASES LCO 3.0.9 (continued)

The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

Reviewers Note -------------------------------------

LCO 3.0.9 may be expanded to other initiating event categories provided plant-specific analysis demonstrates that the frequency of the additional initiating events is bounded by the generic analysis or if plant-specific approval is obtained from the NRC.

  • Loss of coolant accidents;
  • High energy line breaks;
  • External flooding;
  • Tornado or high wind.

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train Babcock & Wilcox STS B 3.0-14 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

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

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and Babcock & Wilcox STS B 3.0-19 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

Westinghouse STS B 3.0-5 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.9 (continued)

The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

REVIEWER'S NOTE-----------------------------------

LCO 3.0.9 may be expanded to other initiating event categories provided plant-specific analysis demonstrates that the frequency of the additional initiating events is bounded by the generic analysis or if plant-specific approval is obtained from the NRC.

  • Loss of coolant accidents;
  • High energy line breaks;
  • External flooding;
  • Tornado or high wind.

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train Westinghouse STS B 3.0-14 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensees Corrective Action Program.

Westinghouse STS B 3.0-20 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

Combustion Engineering STS B 3.0-5 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.9 (continued)

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train protects against internal flooding and the affected barrier for the other train protects against tornado missiles. In this example, the affected barrier may be the same physical barrier but serve different protection functions for each train.

If during the time that LCO 3.0.9 is being used, the required OPERABLE train or subsystem becomes inoperable, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the train(s) or subsystem(s) supported by barriers that cannot perform their related support function(s) must be declared inoperable and the associated LCOs declared not met. This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period provides time to respond to emergent conditions that would otherwise likely lead to entry into LCO 3.0.3 and a rapid plant shutdown, which is not justified given the low probability of an initiating event which would require the barrier(s) not capable of performing their related support function(s). During this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the plant risk associated with the existing conditions is assessed and managed in accordance with 10 CFR 50.65(a)(4).

Combustion Engineering STS B 3.0-15 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

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

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant Combustion Engineering STS B 3.0-19 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

General Electric BWR/4 STS B 3.0-5 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.9 (continued)

The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

REVIEWER'S NOTE-----------------------------------

LCO 3.0.9 may be expanded to other initiating event categories provided plant-specific analysis demonstrates that the frequency of the additional initiating events is bounded by the generic analysis or if plant-specific approval is obtained from the NRC.

  • Loss of coolant accidents;
  • High energy line breaks;
  • External flooding;
  • Tornado or high wind.

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for General Electric BWR/4 STS B 3.0-14 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

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

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and General Electric BWR/4 STS B 3.0-20 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.

Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

General Electric BWR/6 STS B 3.0-5 Rev. 4.0

TSTF-581, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.9 (continued)

The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

REVIEWER'S NOTE-----------------------------------

LCO 3.0.9 may be expanded to other initiating event categories provided plant-specific analysis demonstrates that the frequency of the additional initiating events is bounded by the generic analysis or if plant-specific approval is obtained from the NRC.

  • Loss of coolant accidents;
  • High energy line breaks;
  • External flooding;
  • Tornado or high wind.

The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provision of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.9 may be applied for up to 30 days for more than one trains of a multiple trains supported system if the affected barrier for General Electric BWR/6 STS B 3.0-14 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued)

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action General Electric BWR/6 STS B 3.0-19 Rev. 4.0

TSTF-581, Rev. 0 SR Applicability B 3.0 BASES SR 3.0.3 (continued) specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensees Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay AP1000 STS B 3.0-16 Rev. 0

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