Text

Submittal for Information of TSTF-GG-21-01, Technical Requirements Manual and Operational References (TRM) Format and Content Guideline
	ML21137A033
Person / Time
Site:	Technical Specifications Task Force, 99902042
Issue date:	05/17/2021
From:	Joyce J, Miksa J, Demetrius Murray, Sparkman W, Vaughan J; Technical Specifications Task Force
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-21-02
	Download: ML21137A033 (68)
	v • d • e

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF May 17,2021 TSTF-21-02 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Submittal for Information of TSTF-GG-21-01, "Technical Requirements Manual and Operational References (TRM) Format and Content Guideline" Enclosed is an industry guidance document, TSTF-GG-21-01, "Technical Requirements Manual and Operational References (TRM) Format and Content Guideline." The document is being provided to the NRC for information only and review of the document is not being requested.

The sponsors of the TSTF, the Boiling Water Reactor Owners' Group (BWROG) and Pressurized Water Reactor Owners Group (PWROG), developed the guidance document to provide the recommended format and content of the Technical Requirements Manual (TRM),

which is also called by other names, such as the Operational Requirements Manual, Selected Licensee Commitments, or Licensee Controlled Specifications. The guidance document incorporates industry best practices as well as new approaches.

Should you have any questions, please do not hesitate to contact us.

James P. Miksa (PWROG/CE)

Ryan M. Joyce (BWROG)

Dwi Murray (PWROG/W)

Jordan L. Vaughan (PWROG/B&W)

Wesley Sparkman (PWROG/AP1000)

Enclosure cc:

Michelle Honcharik, Technical Specifications Branch Victor Cusumano, Technical Specifications Branch

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TSTF-GG-21-01, Revision 0 TECHNICAL REQUIREMENTS MANUAL AND OPERATIONAL REFERENCES (TRM) FORMAT AND CONTENT GUIDELINE APRIL 2021

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ACKNOWLEDGMENTS This document, "Technical Requirements Manual and Operational References (TRM)

Format and Content Guideline," was developed by the Pressurized Water Reactor Owners Group Licensing Committee and the Boiling Water Reactors Owners' Group Licensing Committee. The Core Team that developed the document included:

Ryan Joyce, (Southern Company) (Core Team Lead)

Jim Andrachek (Westinghouse)

C.J. Collins (Southern Company)

Matthew Cox (Arizona Public Service)

William Garrett (Southern Company)

Lee Grzeck (Duke Energy)

Shane Jurek (Talen Energy)

Brian Mann (EXCEL Services Corporation)

Mitchel Mathews (Exelon Nuclear)

Ken Nicely (Exelon Nuclear)

Michael Richardson (Pacific Gas and Electric)

Michael Scarpello (American Electric Power)

John Schrage (Entergy)

Sara Scott (Xcel Energy)

The TSTF is grateful for their valuable contributions.

TSTF-GG-21-01, Rev. 0 April 2021 ii TABLE OF CONTENTS 1.0 Overview................................................................................................................. 1 2.0 TRM Incorporation by Reference in the UFSAR................................................... 2 3.0 Technical Requirement Surveillance (TRS) Changes............................................ 3 3.1 TRS Acceptance Criteria Changes or Elimination........................................ 3 3.2 TRS Frequency Changes................................................................................ 3 4.0 Example TRM......................................................................................................... 6 4.1 TRM Terms, Numbering, and Formatting..................................................... 7 4.2 TRM Content................................................................................................. 8 4.2.1 Completion Time Maintenance Rule Backstop............................................. 8 4.2.2 Revision to the TRS Applicability Requirements.......................................... 9 4.2.3 Elimination of Shut Down Actions................................................................ 9 4.2.4 Use of the Term "Functional" Instead of "Operable" in the TRM............... 10 4.2.5 Elimination of Mode Change Restrictions................................................... 10 4.2.6 Simplification of Definitions and Applicability Rules................................ 10 4.2.7 Elimination of NRC Reporting Requirements............................................. 12 4.2.8 Elimination of Required Actions to Declare TS Systems Inoperable.......... 12 5.0 Other Considerations............................................................................................ 12 5.1 Retention of the Structural Integrity Technical Requirement...................... 12 Appendix A Example Technical Requirements Manual and Operational References Document Appendix B Example Applicability Determinations

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1.0 Overview This document provides recommendations on the format and content for a plant's Technical Requirements Manual (TRM), which is also called by other names, such as the Operational Requirements Manual, Selected Licensee Commitments, or Licensee Controlled Specifications.

The TRM is not an NRC-required document. NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-100, "Control of Licensing Bases for Operating Reactors,"

discusses the TRM. It states that the TRM is controlled by the licensee under the provisions of 10 CFR 50.59.

The TRM is a licensee-controlled document typically created during conversion to the Improved Technical Specifications (ITS). Specifications that do not satisfy the 10 CFR 50.36(c)(2)(ii) criteria for retention in the plant's Technical Specifications (TS) are moved to the TRM. As discussed in TSTF-GG-13-01, "Improved Technical Specifications Conversion Guidance":

Many utilities have chosen to develop a licensee-controlled manual that contains many of the relocated Technical Specifications. This manual is incorporated by reference into the UFSAR. This manual is typically called a Technical Requirements Manual (TRM), but other titles have been used. The document is formatted similar to the ITS. All changes made to the relocated technical specifications after being placed in the TRM must be evaluated under 10 CFR 50.59. As requirements are moved from the Technical Specifications to the TRM, shutdown requirements, special report submittals, and other unnecessary restrictions may be evaluated under 10 CFR 50.59 and eliminated. It is important to note that all subsequent changes to any relocated technical specifications must be documented and evaluated under 10 CFR 50.59.

In this document, the phrase reviewed under 10 CFR 50.59 does not mean that a 10 CFR 50.59 screening or evaluation is required. The phrase speaks to application of the regulation in total, recognizing that 10 CFR 50.59(c)(4) requires the review to be completed under the regulation that establishes more specific criteria for accomplishing the change. Licensees should follow their administrative processes that are used to implement 10 CFR 50.59 to review changes to the TRM.

Plants, including those plants that have not converted to the ITS, have developed TRMs to include other items; for example, individual specifications relocated from their TS, fire protection requirements, containment isolation valve lists, and instrument response time lists. The TRM may contain items that were never in the TS, such as Leading Edge Flow Meter (LEFM) requirements for a power uprate.

During conversion to the ITS, licensees could have relocated requirements from the TS to existing plant documents. However, in the midst of a large and complex conversion project, most licensees chose to place the relocated requirements in a TRM with plans to move the requirements to other plant documents in the future. Because the TRM was

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viewed as a temporary document, no guidance was developed on its format or content and, as a result, the format, content, and change control of the TRM varies across the operating fleet. This document provides industry endorsed guidance on these topics.

2.0 TRM Incorporation by Reference in the UFSAR As discussed in TSTF-GG-13-01, changes to TRM requirements are reviewed under 10 CFR 50.59. In early ITS conversion amendments (in particular, those before the 10 CFR 50.59 rule change in 1999), licensee's amendment requests and the NRC's safety evaluation stated that most relocated TS requirements were being moved to the TRM, which would be incorporated by reference in the UFSAR. This was appropriate because the intent was to review changes to the the relocated requirements under 10 CFR 50.59 and, prior to the 1999 rule change, only a revision to the UFSAR wording required a 10 CFR 50.59 review. However, the 1999 rule change altered the 10 CFR 50.59 scope to extend beyond the UFSAR's wording to changes that affect a design function described in the UFSAR. Secondly, it included 10 CFR 50.59(c)(4) which directed that 10 CFR 50.59 would not apply when the applicable regulations establish more specific criteria for evaluating the change. As a result, later ITS conversion amendments stated that the TS requirements were being relocated to the TRM which would be controlled under 10 CFR 50.59 and did not state that the TRM would be incorporated by reference into the UFSAR.

Licensees that have incorporated the TRM by reference may continue to do so, and to provide TRM updates to the NRC in accordance with 10 CFR 50.71(e). However, if desired a licensee may change the TRM to a general reference in the UFSAR as an administrative change and continue to review changes to the TRM under 10 CFR 50.59.

This is consistent with NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports," Section A4.3 "Referencing Other Documents in Updated FSARs."

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3.0 Technical Requirement Surveillance (TRS) Changes 3.1 TRS Acceptance Criteria Changes or Elimination TRS acceptance criteria satisfy 10 CFR 50, Appendix B, Criterion XI, "Test Control,"

which states, "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents."

To change a TRS acceptance criteria (including elimination of the TRS entirely), the licensee should determine the design function of the tested structure, system, or component (SSC) and whether the design function is affected by the TRS change. Design functions are defined in NEI 96-07, "Guidelines for 10 CFR 50.59 Implementation." If the TRS is necessary to verify that a design function can be fulfilled (e.g., the verification is not required under another licensee program or procedure), then the change should be reviewed under 10 CFR 50.59. If a TRS is relocated from the TRM and the test is placed in another licensee program or procedure, this can be processed as an administrative change.

Also see NEI 96-07, Section 4.1.2, "Maintenance Activities," subpart, "Control of Maintenance Procedures."

3.2 TRS Frequency Changes TRS Frequencies are controlled by the licensee. Per 10 CFR 50.59(c)(4), the provisions of 50.59 do not apply if a more applicable regulation establishes more specific criteria for accomplishing such changes. As discussed in NEI 96-07, "Guidelines for 10 CFR 50.59 Implementation," Section 4.1.2, "Maintenance Activities," "Control of Maintenance Procedures":

Changes to procedures for performing maintenance are made in accordance with applicable 10 CFR Part 50, Appendix B, criteria and licensee procedures. Licensee processes should ensure that changes to plant configurations called for by procedures are consistent with the technical specifications. 10 CFR 50.59 does not apply to such changes because, like the maintenance activities themselves, changes to procedures for performing maintenance do not permanently alter the design, performance requirements, operation or control of SSCs.

The applicable Appendix B criterion is Criterion XI, "Test Control." Compliance with this criterion is described in the licensee's Quality Assurance Topical Report.

To justify a change to a TRS frequency, the licensee should conclude that the new frequency will ensure the component will function as designed using the licensee's applicable change process.

See Figure 1 for an example of the considerations when changing a TRS Frequency.

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Unless the TRS Frequency is credited in the safety analysis (for example, turbine tests credited in determining turbine missile probability), a 10 CFR 50.59 review is not required for changing a TRS Frequency even if the proposed change results in changes to the UFSAR. The 10 CFR 50.59 criteria establish conditions under which licensees may make changes to the facility or procedures and conduct tests or experiments without prior NRC approval. Per the definitions of "facility," "procedures," and "tests or experiments" in the regulation and in NEI 96-07, TRS frequencies do not qualify as any of these three terms.

The regulatory requirement to update the UFSAR is governed by 10 CFR 50.71, not 10 CFR 50.59.

For those licensees that have a license condition permitting alternative treatment of SSCs pursuant to 10 CFR 50.69, the testing frequency of components that have been categorized as RISC-3 is governed by 10 CFR 50.69, not Appendix B. Since 10 CFR 50.69 only requires reasonable confidence that the component can perform its safety-related function under design basis conditions, it is acceptable to change the TRS Frequency based on that standard.

If a TRS and its frequency are related to a TS SR and its frequency (for example, as part of the same test procedure), an evaluation to change the TS SR frequency under the TS Surveillance Frequency Control Program (SFCP) does not justify a change to the corresponding TRS frequency. The SFCP only applies to TS SR frequencies. However, portions of the technical information in the SFCP evaluation can be used to inform the TRS frequency change evaluation.

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Figure 1

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4.0 Example TRM Appendix A provides an example TRM, called the "Technical Requirements Manual and Operational References." The acronym "TRM" is retained due to its common use. The example TRM was developed to provide an example of the recommended format and content of plant-specific TRMs.

Example TRs are included in each chapter, but not all TRs that may appear in a plant TRM are included in the example. Some typical TRs in plant TRMs are:

Area Radiation Monitors Boration / Makeup Systems BWR Control Rod Block Instrumentation Communications Containment Penetration Conductor Overcurrent Protective Devices Decay Time Before Fuel Movement Fire Detection and Protection Instrumentation and Equipment, Emergency Lighting, or NFPA 805 Equipment FLEX-Related Requirements Fuel Handling Machine / Spent Fuel Pool Crane Limitations Hydrogen monitors/recombiners LEFM Requirements Meteorological Instrumentation MOV Thermal Overload Protection Pressurizer heatup/cooldown PWR Loose Parts Monitoring Radiation Monitoring Instrumentation RCS Chemistry Reactor Vent Valves Refueling Interlocks Sealed Source Contamination Secondary Coolant Chemistry Seismic Monitoring Instrumentation SG heatup/cooldown Snubbers Structural Integrity of ASME Class 1, 2, and 3 Components Toxic Gas Detection Instrumentation Turbine Overspeed Protection Waste Gas & Liquid Storage & Holdup Tanks Westinghouse Movable Incore Detectors Licensees using this document may adopt all of the recommendations in the example TRM as discussed in this chapter or may choose which aspects to incorporate in their plant-specific TRM.

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4.1 TRM Terms, Numbering, and Formatting The example TRM uses defined terms, such as "Technical Requirement (TR)", which is analogous to a TS Limiting Condition for Operation, and "Technical Requirement Surveillance (TRS)," which is analogous to a TS Surveillance Requirement. Terms that are also used in the TS, such as "Applicability," "ACTIONS," "Completion Times," and "IMMEDIATELY" are used because they are applicable to the situation and are well understood. However, licensees using this document may choose other appropriate terms.

There is one exception: It is recommended to not use the term "operable" in the TRM instead of "functional" as the term describing the ability of the subject system to perform its function. Using "operable" in the TRM could cause confusion between the TRM requirements and the TS requirements (i.e., "operable" only applies to TS).

The plant-specific numbering of TRM requirements varies widely across the fleet. After considering several alternatives, the example TRM chapter numbers start at eleven. This clearly and easily distinguishes the TRM requirements from the analogous TS requirements. For example, TS Section 3.8 describes electrical power systems. TRM Section 13.8 also describes electrical power systems. Similarly, TRM TR 13.0.1 is like TS LCO 3.0.1.

The example TRM largely follows the format of the Standard Technical Specifications (STS). This format was chosen for the STS based on human factors studies and is familiar to operators at plants with TS based on the STS (approximately three-fourths of the operating fleet). However, plants may choose other formats.

The example TRM places the Bases discussing a TR following the TR instead of in a separate document. The TS and Bases in the STS are separated because the TS are part of the license and controlled by the NRC, while the Bases are controlled by the licensee.

However, the ownership and control of the TRs and the Bases resides with the licensee.

Therefore, it makes the document easier to use if the TR and the associated Bases are located together.

The example TRM contains Bases with less detail than the STS. The level of detail in the TRM Bases is left to the licensee. If the existing TRM Bases contain more detail than the example, they can be retained or simplified.

A new informational section, labeled "Support Function," is added to the TRM as an operator aid. Some TRs provide support functions for the TS systems. If that is the case, it is documented in this section of the TRM. If the system does not support a TS system, that is stated.

The example TRM includes Chapter 16, titled, "Operational References." The chapter contains information, typically in tabular form, that is referenced from other requirements.

The Operational References are not requirements but are supporting information used by other requirements. The Operational References contain a section titled, "Reference," that describes the requirement that uses the information.

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4.2 TRM Content The example TRM incorporates many content improvements. These content improvements can be adopted by a licensee without adopting the terms, numbering, or formatting in the example TRM. Example 10 CFR 50.59(c)(4) Applicability Determinations are included in Appendix B when appropriate as noted below. None of the changes required a 10 CFR 50.59 screen or evaluation. However, the licensee should exercise caution when applying the guidance and ensure that 10 CFR 50.59 review is conducted on the licensee's current licensing basis and in accordance with their procedures.

4.2.1 Completion Time Maintenance Rule Backstop In the example TRM, all TR Required Actions that specify that a nonfunctional SSC must be restored to functional status have two Completion Times: A fixed Completion Time (referred to as the "front stop") and an optional Completion Time based on the licensee-established performance criteria required by 10 CFR 50.65(a)(4) (known as the "Maintenance Rule backstop"). The latter is stated as "OR In accordance with the Maintenance Rule." The front stop Completion Time may always be used.

The Maintenance Rule requires that licensees "... monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken." Licensees applying a Maintenance Rule backstop to an SSC must verify that the SSC is within the Maintenance Rule scope.

Use of the Maintenance Rule backstop is elective and may be used after the front stop Completion Time is in use or has been exceeded. A licensee may not always have the information readily available to determine an acceptable Maintenance Rule backstop for an SSC. In addition, licensees have flexibility in establishing Maintenance Rule performance criteria and not all performance criteria are time-based. In that case, the Maintenance Rule backstop could not be used. However, for example, if a utility wanted to maintain an availability of 95 percent for a particular system because that was an assumption used in the site's Probabilistic Risk Assessment (PRA), then the 95 percent value could be the performance criteria. This availability criteria could be used to establish an acceptable Completion Time for a nonfunctional system.

If desired, a licensee could eliminate front stop Completion Times and use only the Maintenance Rule Completion Times. However, the front stops are convenient for short-duration, expected activities such as testing and routine maintenance. A licensee could extend a front stop Completion Time using the same justification used to add the Maintenance Rule backstop. Licensees should recognize that plant conditions could result in Maintenance Rule evaluations that require action prior to exceeding the front stop Completion Times.

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This change is evaluated in Appendix B.

4.2.2 Revision to the TRS Applicability Requirements STS SR 3.0.2 states that the specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency. STS SR 3.0.3 states that if it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed up to the limit of the specified Frequency. Most TRMs have similar allowances on testing frequency.

In the example TRM, TRS 13.0.2 defines the specified Frequency as 1.25 times the Frequency stated in the TRS. If a TRS is not performed within the specified Frequency, a Condition Report is initiated to determine if the associated TR is met and the TRS should be performed at the first reasonable opportunity. If it is discovered that a TRS was not performed within its specified Frequency, the same actions are applied.

It is important to note that the use of "met" or "performed" conveys specific meanings. A TRS is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a TRS, even without a TRS specifically being "performed," constitutes a TRS not "met" and under TRS 13.0.1, the associated TR is not met. "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria by performance of the TRS.

This change is evaluated in Appendix B.

4.2.3 Elimination of Shut Down Actions None of the ACTIONS in the example TRM specify that a unit must be shut down. The terminal action of all TRM ACTIONS is to create a Condition Report in accordance with the licensee's Corrective Action Program. This change is also made to TR 13.0.3, which is the applicable requirement if a TR's ACTIONS are not met or an ACTION was not provided.

As an alternative to requiring creation of a Condition Report, the existing TRM Action that requires a plant shutdown could be deleted. If no TR ACTION is applicable, TR 13.0.3 applies. TR 13.0.3 requires creating a Condition Report.

There is no regulatory requirement for a plant shutdown due to not meeting a TRM condition. NRC Office of Nuclear Reactor Regulation Office Instruction LIC-100, Revision 1, "Control of Licensing Bases for Operating Reactors", Section 3.1.2, "Technical Requirements Manual," states, There should be no confusion that action statements or other aspects of the TRM can be changed by licensees using the process defined in 10 CFR 50.59. This includes those relocated provisions that defined allowable outage times or required actions, including plant shutdowns.

TSTF-GG-21-01, Rev. 0 April 2021 10 This change is evaluated in Appendix B.

4.2.4 Use of the Term "Functional" Instead of "Operable" in the TRM The example TRM defines the term "FUNCTIONAL/FUNCTIONALITY" as, "A system, structure, or component (SSC) is FUNCTIONAL or has FUNCTIONALITY when it is capable of performing its function(s) as described in the design and licensing basis.

FUNCTIONALITY includes the ability of required support systems to perform their related support function(s) for equipment required to be OPERABLE by the TS."

As described in NEI 18-03, "Operability Guidelines," "The terms 'operable' or 'operability' do not appear in laws or regulations related to commercial nuclear power. The terms are defined in the technical specifications (TS) for each plant and, therefore, only have meaning as used relative to that document."

Noncompliance with a TR should be addressed under the Corrective Action Program. Any consideration of the effect on the operability of TS systems should be performed under the Corrective Action Program, consistent with licensee procedures.

The TRM term "functional" has an equivalent definition as the term "operable" in the existing plant TRM. Replacing the term "operable" or "operability" in the existing plant TRM with "functional" or "functionality" is an administrative change to distinguish the TRM requirements from the TS requirements.

4.2.5 Elimination of Mode Change Restrictions STS LCO 3.0.4 prohibits entering the Mode or other specified condition in the Applicability when the LCO is not met, unless LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c applies. LCO 3.0.4.b permits entering Modes with the LCO not met if risk is assessed and managed with some exceptions. STS SR 3.0.4 prohibits entry into a Mode or other specified condition in the Applicability if the LCO's Surveillance Requirements are not met, except as permitted by LCO 3.0.4.

The example TRM does not include an equivalent to STS LCO 3.0.4 or STS SR 3.0.4 and there is no restriction on entering a Mode or other condition in the Applicability with a TR or TRS not met. However, if a Mode or other specified condition in the Applicability is entered with a TR not met, the associated ACTIONS must be followed. If a Mode or other specified condition in the Applicability is entered with a TRS not met, TRS 13.0.2 requires that a Condition Report be initiated to determine if the associated TR is met.

This change is evaluated in Appendix B.

4.2.6 Simplification of Definitions and Applicability Rules Section 11.1, Definitions The example TRM contains only terms that are used in the TRM and does not rely on the TS for defined terms. It is not recommended to reference the TS for defined terms, as the

TSTF-GG-21-01, Rev. 0 April 2021 11 TS definitions frequently refer to "operability" which is not applicable to TRM requirements. In developing a plant-specific TRM, licensees should include any instrument testing definitions used in the TRM, replacing the terms "operable" or "operability" with "functional" or "functionality" and removing any references to the Surveillance Frequency Control Program.

In the example TRM the definition of "Immediately" as used as a Completion Time is moved to the definitions section instead of the TRM section equivalent to Section 1.3 in the STS. As a result, the term "Immediately" is capitalized in the TRM.

The changes to the definitions are administrative, in that eliminating unused definitions or using TRM definitions that are equivalent to TS definitions does not change the TRM requirements.

Sections 11.2, "Logical Connectors," 11.3, "Completion Times," and 11.4, "Frequency" Section 11.2, "Logical Connectors," references the TS Section 1.2, "Logical Connectors."

There is no advantage in repeating this TS section in the TRM. Licensees that do not use the STS format for their TRM should not include this section.

Section 11.3, "Completion Times," and Section 11.4, "Frequency," are simplified versions of the corresponding sections of the STS. Where needed, the TS terms, such as "operable,"

"LCO, and "SR" are revised to use the equivalent term from the TRM. Only the information relevant to the TRM is retained. The examples are not included in the TRM.

The changes to the Sections 11.2, 11.3, and 11.4 are administrative, in that eliminating unused explanations and examples and substituting equivalent terms does not change the TRM requirements.

Section 13.0.1, TR and TRS Applicability The example TRM TR 13.0 contains simplified versions of the STS usage rules. These simplified versions provide the guidance needed to follow the TRM requirements while eliminating unnecessary complexity.

STS LCO 3.0.5 is an exception to LCO 3.0.2 that permits not following the TS ACTIONS to perform testing to establish OPERABILITY. It is incorporated into TRM TR 13.0.2 to simplify the presentation, but with no change in implementation. This is an administrative change.

STS LCO 3.0.6 provides an exception to not follow the Actions for inoperable TS equipment that provides a support function to other TS equipment. There are few, if any, support/supported relationships in the TRM. Therefore, the TRM equivalent of the exception in STS LCO 3.0.6 is not needed in the TRM and can be removed as an administrative change.

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STS LCO 3.0.7 addresses test exceptions and the TRM does not include any test exceptions. Therefore, the TRM equivalent of LCO 3.0.7 can be removed as an administrative change.

STS LCO 3.0.8 and LCO 3.0.9 provide exceptions to declaring systems inoperable if required snubbers or barriers are not capable of performing their required support functions. Few, if any, SSCs described in the TRM are supported by snubbers or barriers. Any such systems can be declared nonfunctional if a required snubber or barrier is incapable of performing the required support function. Therefore, the TRM equivalent of LCO 3.0.8 and LCO 3.0.9 can be removed as an administrative change.

STS SR 3.0.1 requires that SRs be met. TRS 13.0.1 is revised to use the example TRM terminology but the requirements are not changed. This is an administrative change.

4.2.7 Elimination of NRC Reporting Requirements Some plant TRMs retained requirements to send reports to the NRC that were in the plant TS. The example TRM in Appendix A contains no such reporting requirements. In relocating reporting requirements from the TS to the TRM, the NRC understood that those reporting requirements could be deleted by the licensee.

This change is evaluated in Appendix B.

4.2.8 Elimination of Required Actions to Declare TS Systems Inoperable Some plant TRMs contain Required Actions that direct that TS systems be declared inoperable. These Required Actions do not appear in the example TRM.

The TRM cannot change the TS definition of operability and the inclusion or exclusion of TRM Required Actions does not affect the licensee's responsibility to assess operability of TS systems when a degraded condition is discovered. The TRM Required Action could conflict with the licensee's operability determination process or mislead an operator that TS operability does not need to be assessed unless specified in the TRM.

This change is evaluated in Appendix B.

5.0 Other Considerations 5.1 Retention of the Structural Integrity Technical Requirement Many plant-specific TRMs contain a requirement relocated from the plant TS with a title similar to, "ASME Code Class 1, 2, and 3 Components." The TRM typically states, "The structural integrity of ASME Code Class 1, 2, and 3 components shall be maintained in accordance with the Inservice Inspection Program." It would appear that this TRM requirement duplicates the requirements of 10 CFR 50.55a and the Inservice Testing Program and could be removed from the TRM. However, at least two plants have received

TSTF-GG-21-01, Rev. 0 April 2021 13 violations for attempting to remove the "ASME Code Class 1, 2, and 3 Components" TR from their TRM.

The NRC inspection report dated October 29, 2012, for the LaSalle County Station (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12303A047) describes the violation.

The NRC inspection reports dated April 15, 2014, and February 5, 2016, for the Donald C. Cook plant (ADAMS Accession No. ML14105A326 and ML16039A333) describe the violations.

In each case, the NRC determined that the actions required by the ASME Code, Corrective Action Program, Operability Determination Program, or TS, credited in the evaluation of the TRM change, would not result in the immediate actions required by the TRM, and, therefore, required a full 50.59 evaluation.

Licensees considering alteration or removal of this TRM requirement are advised to review these violations.

TSTF-GG-21-01, Rev. 0 April 2021 Appendix A Example Technical Requirements Manual and Operational References Document

Station Name/Unit Document Designation

[COMPANY]

[STATION NAME / UNIT]

Technical Requirements Manual and Operational References (TRM)

Revision ##

Station Name/Unit Document Designation i

Revision ##

PURPOSE The Technical Requirements Manual and Operational References (TRM) contains design and licensing basis technical requirements that do not appear in the Technical Specifications (TS). It also contains operational references.

Chapter 13 of this document includes TECHNICAL REQUIREMENTS (TRs),

TECHNICAL REQUIREMENT SURVEILLANCES (TRSs), and ACTIONS. Instructions for the use and application of the TRs, TRSs, and ACTIONS are included in Section 13.0.

Chapter 16 of this document includes operational references. Operational references provide a readily accessible collection of setpoints, lists, and other helpful tools described in plant procedures, programs, and TS. Operational references are not requirements, but may be referenced from requirements, such as the list of [Primary]

Containment Isolation Valves which is used to apply the corresponding TS.

The TRM is a licensee document controlled under 10 CFR 50.59.

The TRM may reference the plant TS. However, the TRM cannot change TS requirements.

[Station Name]

ii Revision ##

[Unit #]

TABLE OF CONTENTS Page 11.0 USE AND APPLICATION 11.1 Definitions................................................................................................. 11-1 11.2 Logical Connectors................................................................................... 11-2 11.3 Completion Times.................................................................................... 11-2 11.4 Frequency................................................................................................ 11-3 12.0 SAFETY LIMITS 13.0 TECHNICAL REQUIREMENT (TR) APPLICABILITY................................. 13.0-1 13.0 TECHNICAL REQUIREMENT SURVEILLANCE (TRS) APPLICABILITY.. 13.0-2 13.1 REACTIVITY CONTROL SYSTEMS 13.1.1 Boration Systems - Operating........................................................... 13.1.1-1 13.2 POWER DISTRIBUTION LIMITS 13.3 INSTRUMENTATION 13.3.1 Moveable Incore Detection System.................................................... 13.3.1-1 13.3.2 Seismic Monitoring Instrumentation................................................... 13.3.2-1 13.4 REACTOR COOLANT SYSTEM 13.4.1 Chemistry........................................................................................... 13.4.1-1 13.5 EMERGENCY CORE COOLING SYSTEMS 13.6 CONTAINMENT SYSTEMS 13.6.1 Hydrogen Recombiners...................................................................... 13.6.1-1 13.7 PLANT SYSTEMS 13.7.1 Steam Generator (SG) Pressure/Temperature Limitation.................. 13.7.1-1 13.8 ELECTRICAL SYSTEMS 13.8.1 Motor Operated Valve (MOV) Thermal Overload Protection Devices............................................................................................... 13.8.1-1 13.9 REFUELING OPERATIONS 13.9.1 Communications................................................................................. 13.9.1-1 13.10 SPECIAL OPERATIONS [BWR ONLY]

13.11 RADIOLOGICAL EFFLUENTS 13.11.1 Gas Storage Tanks.......................................................................... 13.11.1-1 13.12 FIRE PROTECTION 13.12.1 Halon Systems................................................................................. 13.12.1-1 14 DESIGN FEATURES

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TABLE OF CONTENTS Page 15 ADMINISTRATIVE CONTROLS 15.1 Site Fire Brigade.................................................................................... 15.1-1 16.0 OPERATIONAL REFERENCES 16.1 Containment Isolation Valves...................................................................... 16.1-1

USE AND APPLICATION 11.0

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11.0 USE AND APPLICATION 11.1 Definitions

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout the TRM.

Term Definition ACTIONS ACTIONS shall be that part of a TR that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel FUNCTIONALITY.

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

FUNCTIONAL/FUNCTIONALITY A system, structure, or component (SSC) is FUNCTIONAL or has FUNCTIONALITY when it is capable of performing its function(s) as described in the design and licensing basis. FUNCTIONALITY includes the ability of required support systems to perform their related support function(s) for equipment required to be OPERABLE by the TS.

IMMEDIATELY When IMMEDIATELY is used as a Completion Time, the ACTIONS should be pursued without delay and in a controlled manner.

USE AND APPLICATION 11.0

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11.1 Definitions MODE A MODE shall correspond to any one of the operating conditions specified in Table 1.1-1 of the TS with fuel in the reactor vessel.

OPERABLE/OPERABILITY A system, structure, or component (SSC) is OPERABLE or has OPERABILITY when a TS Limiting Condition for Operation requires it to be OPERABLE and the TS OPERABILITY requirements are met. The terms OPERABLE and OPERABILITY do not apply to SSCs that are not required to be OPERABLE by a TS Limiting Condition for Operation.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of [2893] MWt.

TECHNICAL REQUIREMENT (TR) A TR is a requirement specified or assumed in the design or licensing basis.

TECHNICAL REQUIREMENT A TRS is a test or verification required by the design SURVEILLANCE (TRS) or licensing basis.

TECHNICAL SPECIFICATIONS The TS are those requirements which satisfy (TS) 10 CFR 50.36 and which are issued as an appendix to the plant's license.

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

USE AND APPLICATION 11.0

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11.0 USE AND APPLICATION 11.2 Logical Connectors The guidance provided for the use and application of logical connectors in Section 1.2, Logical Connectors of the TS is also applicable to the logical connectors in TRs, ACTIONS, and TRSs contained in this manual.

11.3 Completion Times The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., TR not met) unless otherwise specified.

Once an ACTION has been entered, subsequent trains, subsystems, components, or variables expressed in the TR, discovered to be not be FUNCTIONAL or not within limits, will not result in separate entry into the ACTION, unless specifically stated. The Completion Times are based on initial entry into the ACTION, unless otherwise specified.

Completion Times for Required Actions that state that a structure, system, or component (SSC) must be restored to FUNCTIONAL status have a fixed Completion Time (referred to as the "front stop") and the option to determine a Completion Time based on the licensee-established performance goals required by 10 CFR 50.65(a)(4) (referred to as the "Maintenance Rule backstop"). The front stop Completion Time may always be used. Use of the Maintenance Rule backstop is elective and may be used after the front stop Completion Time is in use or has been exceeded.

11.4 Frequency Each TRS has a specified Frequency that must be met while in the MODE or other specified conditions of the Applicability or the corresponding TR is not met. The "specified Frequency" consists of the requirements of the Frequency column of each TRS as modified by TRS 13.0.2, as well as certain Notes in the test column that modify performance requirements.

The use of "met" or "performed" conveys specific meanings. A TRS is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a TRS, even without a TRS specifically being "performed," constitutes a TRS not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria.

If the specified Frequency for a TRS is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the associated TRS, it must be performed prior to entry into the MODE or other specified condition or the TRS is considered not met.

SAFETY LIMITS 12.0

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12.0 SAFETY LIMITS Not used.

TR and TRS Applicability 13.0

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13.0 TECHNICAL REQUIREMENT (TR) APPLICABILITY TR 13.0.1 TRs shall be met during the MODES or other specified conditions in the Applicability, except as provided in TR 13.0.2.

TR 13.0.2 Upon discovery of a failure to meet a TR, the ACTIONS shall be met within the Completion Times, with the exceptions specified below.

a.

If the TR is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the ACTION(S) is not required unless otherwise stated.

b.

Administrative controls may be employed in lieu of the specified ACTIONS if necessary to perform testing to verify the FUNCTIONALITY of equipment.

TR 13.0.3 When a TR is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTION, initiate a Condition Report in accordance with the Corrective Action Program.

TR and TRS Applicability 13.0

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13.0 TECHNICAL REQUIREMENT SURVEILLANCE (TRS) APPLICABILITY TRS 13.0.1 TRS shall be met during the MODES or other specified conditions in the Applicability of the associated TR, unless otherwise stated. Failure to meet an TRS, whether such failure is experienced during the performance of the TRS or between performances of the TRS, shall be failure to meet the TR. TRSs do not have to be performed on nonfunctional equipment or variables outside specified limits.

TRS 13.0.2 The specified Frequency for each TRS is met if the TRS is performed within 1.25 times the interval specified in the Frequency as measured from the previous performance, or as measured from the time a specified condition of the Frequency is met.

Should a TRS not be performed within the specified Frequency a Condition Report shall be initiated to determine if the associated TR is met. The TRS shall be performed at the next reasonable opportunity.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..."

basis, the above Frequency extension applies to each performance after the initial performance.

TR and TRS Applicability 13.0

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13.0 TECHNICAL REQUIREMENT (TR) APPLICABILITY AND TECHNICAL REQUIREMENT SURVEILLANCE APPLICABILITY BASES TR 13.0.1 TR 13.0.1 establishes the Applicability statement within each individual requirement for when the TR is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of the requirement).

TR 13.0.2 TR 13.0.2 establishes that upon discovery of a failure to meet a TR, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of a TR are not met. Completing the Required Actions is not required when a TR is met or is no longer applicable, unless otherwise stated in the individual requirement.

TR 13.0.2 provides an allowance for following administrative controls instead of the ACTIONS when necessary to allow the performance of required testing to demonstrate either the FUNCTIONALITY of the equipment that is nonfunctional in accordance with the associated TR or the FUNCTIONALITY of other equipment.

TR 13.0.3 TR 13.0.3 establishes the actions that must be implemented when an LCO is not met and either:

a. An associated Required Action and Completion Time is not met and no other Condition applies;

b. The condition of the unit is not specifically addressed by the associated ACTIONS; or A TR may also direct entry into TR 13.0.3.

Under these conditions, as a minimum, a Condition Report must be initiated in accordance with the Corrective Action Program. Initiation of a Condition Report assures that the plant condition will be corrected as required by 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action."

TR and TRS Applicability 13.0

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BASES TRS 13.0.1 TRS 13.0.1 establishes the requirement that TRSs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the TR apply, unless otherwise specified in the individual TRSs. This TRS is to ensure that tests are performed to verify the FUNCTIONALITY of systems and components, and that variables are within specified limits. TRSs may be performed by means of any series of sequential, overlapping, or total steps provided the entire TRS is performed within the specified Frequency.

TRSs do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated TR are not applicable, unless otherwise specified.

TRSs, including TRSs invoked by Required Actions, do not have to be performed on nonfunctional equipment or variable outside their limits because the ACTIONS define the remedial measures that apply. TRSs have to be met and performed in accordance with TRS 13.0.2 prior to returning equipment to FUNCTIONAL status.

TRS 13.0.2 TRS 13.0.2 establishes the requirements for meeting the specified Frequency for TRSs and for any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.

TRS 13.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates scheduling and considers plant operating conditions that may not be suitable for conducting the TRS (e.g., transient conditions or other ongoing testing or maintenance activities).

If a TRS is not performed within the specified Frequency, or it is determined that a TRS was not performed within the specified Frequency, a Condition Report shall be initiated to determine if the associated TR is met. The TRS shall be performed at the next reasonable opportunity.

Boration Systems - Operating 13.1.1

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13.1 REACTIVITY CONTROL SYSTEMS 13.1.1 Boration Systems - Operating TR 13.1.1 Each of the following boron injection subsystems shall be FUNCTIONAL:

a. A flow path from a FUNCTIONAL boric acid tank via a boric acid transfer pump and a charging pump to the Reactor Coolant System; and

b. A flow path from a FUNCTIONAL refueling water storage tank (RWST) via a charging pump to the Reactor Coolant System.

NOTE---------------------------------------------

The charging pump in the RWST flow path must not be the charging pump in the boric acid tank flow path.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One boron injection subsystem nonfunctional.

A.1 Restore subsystem to FUNCTIONAL status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Maintenance Rule B. Both boron injection subsystems nonfunctional.

OR Required Action and associated Completion Time not met.

B.1 Enter TR 13.0.3.

IMMEDIATELY

Boration Systems - Operating 13.1.1

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TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.1.1 Verify the temperature of the area containing the flow path components from the boric acid tank to the blending tee are 63°F.

7 days TRS 13.1.2 Verify each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

31 days SUPPORT FUNCTION The Boration Systems are not required support functions for any TS system.

BASES The boron injection system ensures that negative reactivity control is available during each mode of facility operation. The components required to perform this function include 1) borated water sources, 2) charging pumps, 3) separate flow paths, and 4) boric acid transfer pumps.

With the RCS average temperature above 350°F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems nonfunctional. Allowable out-of-service periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period.

A note has been added to TR 13.1.1 that requires the charging pump in the RWST flow path to be separate from the charging pump in the boric acid tank flow path. The purpose of this note is to ensure that two separate charging pumps are FUNCTIONAL to support boration capability with the unit in MODES 1-3.

POWER DISTRIBUTION LIMITS 13.2

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13.2 POWER DISTRIBUTION LIMITS Not used.

Moveable Incore Detection System 13.3.1

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13.3 INSTRUMENTATION 13.3.1 Moveable Incore Detection System TR 13.3.1 The Moveable Incore Detector System shall be FUNCTIONAL.

APPLICABILITY:

When the Moveable Incore Detector System is used to perform TS Surveillance Requirements.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Less than 75% of the detector thimbles FUNCTIONAL.

OR Less than 2 moveable detector thimbles per quadrant FUNCTIONAL.

A.1 Initiate action to verify the measurement error is acceptable.

IMMEDIATELY

Moveable Incore Detection System 13.3.1

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TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.3.1.1 Verify 75% of the moveable detector thimbles are FUNCTIONAL.

Prior to performing TS SRs using the moveable incore detector system TRS 13.3.1.2 Verify at least two moveable detector thimbles per reactor quadrant are FUNCTIONAL.

Prior to using the moveable incore detector system to calibrate the excore detectors SUPPORT FUNCTION The moveable incore detector system is used to measure core power distribution in accordance with the TS Section 3.2 TS. The moveable incore detector system is also used to calibrate the excore neuron flux detection system in accordance with TS 3.3.1.

BASES The moveable incore detection system must be FUNCTIONAL with the minimum number of incore detector thimbles in order to ensure the measured power distribution accurately represents the spatial neutron flux distribution of the reactor core.

Seismic Monitoring Instrumentation 13.3.2

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13.3 INSTRUMENTATION 13.3.2 Seismic Monitoring Instrumentation TR 13.3.2 The Seismic Monitoring Instrumentation shown in Table 13.3.2-1 shall be FUNCTIONAL.

APPLICABILITY:

At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required Seismic Monitoring Instruments nonfunctional.

A.1 Restore the required instrumentation to FUNCTIONAL status.

30 days OR In accordance with the Maintenance Rule B. Required Action and associated completion time of Condition A not met.

B.1 Enter TR 13.0.3.

IMMEDIATELY TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.3.2.1 Perform a CHANNEL CHECK.

31 days TRS 13.3.2.2 Perform a CHANNEL FUNCTIONAL TEST.

6 months TRS 13.3.2.3 Perform a CHANNEL CALIBRATION.

18 months

Seismic Monitoring Instrumentation 13.3.2

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SUPPORT FUNCTION The seismic monitoring instrumentation does not support any TS requirements.

BASES The seismic monitoring instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability permits comparison of the measured response to that used in the design basis for the facility.

Seismic Monitoring Instrumentation 13.3.2

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Table 13.3.2-1 (Page 1 of 1)

Seismic Monitoring Instrumentation INSTRUMENTS AND SENSOR LOCATIONS MINIMUM INSTRUMENTS FUNCTIONAL

1.

Force Balance Accelerometer Unit

a. Tendon Gallery Floor, 55 level 1

Trigger Threshold Setpoint: 0.010 g

b. Containment Building floor, 140 level 1

Trigger Threshold Setpoint: 0.020 g

c. Containment Building floor, 80 level 1

Trigger Threshold Setpoint: 0.020 g

d. Control Building floor, 74 level 1

Trigger Threshold Setpoint: 0.010 g

e. Control Building floor, 160 level 1

Trigger Threshold Setpoint: 0.020 g

f. 25 E. of Turbine Bldg. W. side x 189 1

9 S. of Turbine Bldg. S. Side on ground Trigger Threshold Setpoint: 0.010 g

2.

Digital Recorders:

a. Control Room Area, 140 level 1

b. Control Room Area, 140 level 1

c. Control Room Area, 140 level 1

d. Control Room Area, 140 level 1

e. Control Room Area, 140 level 1

f. Control Room Area, 140 level 1

Chemistry 13.4.1

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13.4 REACTOR COOLANT SYSTEM 13.4.1 Chemistry TR 13.4.1 The Reactor Coolant System (RCS) chemistry shall be maintained within the steady state limits specified in Table 13.4.1-1.

APPLICABILITY:

At all times, except the dissolved oxygen limit is only applicable when Tavg is > 250°F.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more chemistry parameters in excess of Steady State Limit but within the Transient Limit.

A.1 Restore parameter to within Steady State Limit.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Required Action and associated Completion Time not met.

OR One or more chemistry parameters in excess of the Transient Limit.

B.1 Enter TR 13.0.3.

IMMEDIATELY C. Chloride or Fluoride concentration in excess of its Transient Limit in MODE 5 or 6.

C.1 Perform an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the RCS and to determine that the RCS remains acceptable for continued operation.

Prior to entering MODE 4.

Chemistry 13.4.1

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TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.4.1.1

NOTE-----------------------------

Not required to be performed for Dissolved Oxygen if RCS Tavg 250°F.

Verify the RCS chemistry parameters are within the limits specified in Table 13.4.1-1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SUPPORT FUNCTION The chemistry TR does not support any TS requirements.

BASES The limitations on Reactor Coolant System chemistry ensure that corrosion of the Reactor Coolant System is minimized and reduces the potential for Reactor Coolant System leakage or failure due to stress corrosion. Maintaining the chemistry within the Steady State Limits provides adequate corrosion protection to ensure the structural integrity of the Reactor Coolant System over the life of the plant. The associated effects of exceeding the oxygen, chloride, and fluoride limits are time and temperature dependent. Corrosion studies show that operation may be continued with contaminate concentration levels in excess of the Steady State Limits, up to the Transient Limits, for the specified limited time intervals without having a significant effect on the structural integrity of the Reactor Coolant System. The time interval permitting continued operation within the restrictions of the Transient Limits provides time for taking corrective actions to restore the contaminant concentrations to within the Steady State Limits.

The Surveillance Requirements provide adequate assurance that concentrations in excess of the limits will be detected in sufficient time to take corrective action.

Chemistry 13.4.1

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Table 13.4.1-1 (Page 1 of 1)

Chemistry PARAMETER STEADY STATE LIMIT TRANSIENT LIMIT Dissolved Oxygen 0.10 ppm 1.00 ppm Chloride 0.15 ppm 1.50 ppm Fluoride 0.15 ppm 1.50 ppm

EMERGENCY CORE COOLING SYSTEMS 13.5

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13.5 EMERGENCY CORE COOLING SYSTEMS Not used.

Hydrogen Recombiners 13.6.1

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13.6 CONTAINMENT SYSTEMS 13.6.1 Hydrogen Recombiners TR 13.6.1 Two hydrogen recombiners shall be FUNCTIONAL.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen recombiner nonfunctional.

A.1 Restore hydrogen recombiner to FUNCTIONAL status.

30 days OR In accordance with the Maintenance Rule B. Two hydrogen recombiners nonfunctional.

B.1 Verify by administrative means that the hydrogen control function is maintained.

AND B.2 Restore at least one hydrogen recombiner to FUNCTIONAL status.

Once within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 7 days OR In accordance with the Maintenance Rule C. Required Action and associated Completion Time not met.

C.1 Enter TR 13.0.3.

IMMEDIATELY

Hydrogen Recombiners 13.6.1

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TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.6.1.1 Visually examine each hydrogen recombiner enclosure and verify there is no evidence of abnormal conditions.

6 months TRS 13.6.1.2 Perform a functional test for each hydrogen recombiner.

6 months TRS 13.6.1.3 Perform a CHANNEL CALIBRATION to include a System Functional Test for each hydrogen recombiner.

12 months SUPPORT FUNCTION The hydrogen recombiners do not support any TS function.

BASES The function of the hydrogen recombiners is to eliminate the potential breach of containment due to a hydrogen oxygen reaction. Per 10 CFR 50.44, "Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors," and 10 CFR 50, GDC 41, "Containment Atmosphere Cleanup," hydrogen recombiners are required to reduce the hydrogen concentration in the containment following a Loss of Coolant Accident (LOCA) or Main Steam Line Break (MSLB). Operation with at least one hydrogen recombiner ensures that the post LOCA hydrogen concentration can be prevented from exceeding the flammability limit.

SG Pressure/Temperature Limitation 13.7.1

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13.7 PLANT SYSTEMS 13.7.1 Steam Generator (SG) Pressure/Temperature Limitation TR 13.7.1 The temperatures of the primary coolant and feedwater shall be > 70 °F when the pressure of either coolant in the steam generator is > 200 psig.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. -----------NOTE-------------

All Required Actions must be completed whenever this Condition is entered.

SG temperatures not within limits.

A.1 Reduce the SG pressure of the applicable side to 200 psig.

AND A.2 Perform an engineering evaluation to verify the structural integrity of the SG remains acceptable for continued operation.

30 minutes Prior to increasing the SG coolant temperatures

> 200 °F

SG Pressure/Temperature Limitation 13.7.1

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[Unit #]

TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.7.1.1

NOTE-----------------------------------

Only required to be performed when the temperature of either the primary coolant or feedwater is < 70 °F.

Verify the pressure in each side of the SG is < 200 psig.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SUPPORT FUNCTION The SG pressure/temperature limits support the Reactor Coolant System and Steam Generator TS requirements.

BASES The limitation on steam generator pressure and temperature ensures that the pressure induced stresses in the steam generators do not exceed the maximum allowable fracture toughness stress limits. The limitations of 70°F and 200 psig are based on steam generator average impact values taken at 10°F and are sufficient to prevent brittle fracture.

MOV Thermal Overload Protection Devices 13.8.1

[Station Name]

13.8.1-1 Revision ##

[Unit #]

13.8 ELECTRICAL SYSTEMS 13.8.1 Motor Operated Valve (MOV) Thermal Overload Protection Devices TR 13.8.1 The thermal overload protection devices integral with the motor starter of each valve listed in Table 13.8.1-1 shall be FUNCTIONAL.

APPLICABILITY:

Whenever the MOV is required to be OPERABLE by the TS.

ACTIONS

NOTE--------------------------------------------------------

Separate Condition entry is allowed for each thermal overload protection device.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more thermal overload protection devices nonfunctional.

A.1 Evaluate the FUNCTIONALITY of the affected valve.

IMMEDIATELY TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.8.1.1

NOTE-----------------------------------

CHANNEL CALIBRATION must be performed on each thermal overload device at least once per 12 years.

Verify the required thermal overload protection devices are FUNCTIONAL by performance of a CHANNEL CALIBRATION of a representative sample of at least 25% of all thermal overload devices.

36 months

MOV Thermal Overload Protection Devices 13.8.1

[Station Name]

13.8.1-2 Revision ##

[Unit #]

SUPPORT FUNCTION The MOV thermal overload protection devices may support the OPERABILITY of MOVs required by the TS.

BASES The Technical Requirement Surveillances applicable to lower voltage circuit breakers and fuses provides assurance of breaker and fuse reliability by testing at least one representative sample of each manufacturer's brand of circuit breaker and/or fuse. Each manufacturer's molded case and metal case circuit breakers and/or fuses are grouped into representative samples which are then tested on a rotating basis to ensure that all breakers and/or fuses are tested. If a wide variety exists within any manufacturer's brand of circuit breakers and/or fuses, it is necessary to divide that manufacturer's breakers and/or fuses into groups and treat each group as a separate type of breaker or fuses for surveillance purposes.

The FUNCTIONALITY of the MOV thermal overload protection devices ensures that these devices will not prevent safety related valves from performing their function. The Technical Requirement Surveillances for demonstrating the FUNCTIONALITY of these devices are in accordance with Regulatory Guide 1.106 "Thermal Overload Protection for Electric Motors on Motor Operated Valves," Revision 1, March 1977.

MOV Thermal Overload Protection Devices 13.8.1

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13.8.1-3 Revision ##

[Unit #]

Table 13.8.1-1 (Page 1 of 1)

MOV Thermal Overload Protection Devices VALVE BYPASS DEVICE SYSTEM(S)

NUMBER AFFECTED J-SIA-UV-647 HPSI A Flow Control to Reactor Coolant Valve Safety Injection Shutdown Cooling System J-SIA-UV-637 HPSI A Flow Control to Reactor Coolant Valve Safety Injection Shutdown Cooling System J-SIA-HV-604 HPSI Pump A Long Term Cooling Valve Safety Injection Shutdown Cooling System J-SIB-HV-609 HPSI Pump B Long Term Cooling Valve Safety Injection Shutdown Cooling System J-SIA-HV-657 Shutdown Clg. Temp. Control Train A Valve Safety Injection Shutdown Cooling System J-SIB-HV-658 Shutdown Clg. Temp. Control Train B Valve Safety Injection Shutdown Cooling System J-SIA-HV-686 Ctmt Spray A Cross Connect Valve Safety Injection Shutdown Cooling System J-SIB-HV-696 Ctmt Spray B Cross Connect Valve Safety Injection Shutdown Cooling System

Communications 13.9.1

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13.9.1-1 Revision ##

[Unit #]

13.9 REFUELING OPERATIONS 13.9.1 Communications TR 13.9.1 Direct communications shall be maintained between the control room and personnel at the refueling station.

APPLICABILITY:

During movement of fuel, sources, or reactivity control components in the reactor vessel with the reactor vessel head removed and fuel in the vessel.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Direct communications between the control room and personnel at the refueling station not available.

A.1 Suspend movement of fuel, sources, or reactivity control components in the reactor vessel.

IMMEDIATELY TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.9.1.1 Verify direct communication between the control room and personnel at the refueling station.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

Communications 13.9.1

[Station Name]

13.9.1-2 Revision ##

[Unit #]

SUPPORT FUNCTION Communications during refueling operations does not support any TS function.

BASES The requirement for communications capability ensures that refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity conditions.

SPECIAL OPERATIONS 13.10

[Station Name]

13.10-1 Revision ##

[Unit #]

13.10 SPECIAL OPERATIONS [BWR ONLY]

Not used.

Gas Storage Tanks 13.11.1

[Station Name]

13.11.1-1 Revision ##

[Unit #]

13.11 RADIOLOGICAL EFFLUENTS 13.11.1 Gas Storage Tanks TR 13.11.1 The quantity of radioactivity contained in each gas storage tank shall be limited to 70,500 curies of noble gases (considered as Xe-133).

APPLICABILITY:

At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Quantity of radioactive material in any gas storage tank exceeding limit.

A.1 Suspend all additions of radioactive material to the tank.

AND A.2 Reduce the tank radioactive content to within the limit.

IMMEDIATELY 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

Gas Storage Tanks 13.11.1

[Station Name]

13.11.1-2 Revision ##

[Unit #]

TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.11.1.1

NOTE-----------------------------------

Only required to be performed on a storage tank when radioactive materials are being added to that storage tank.

Verify quantity of radioactive material contained in each gas storage tank to be less than the limit.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when quantity of radioactivity in the tank > one-half the limit.

AND 7 days when quantity of radioactivity in the tank one-half the limit.

SUPPORT FUNCTION The gas storage tanks do not support any TS function.

BASES Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem. This is consistent with the analysis in Updated Final Safety Analysis Report Section [15.7.1], "Waste Gas System Failure".

Halon Systems 13.12.1

[Station Name]

13.12.1-1 Revision ##

[Unit #]

13.12 FIRE PROTECTION 13.12.1 Halon Systems TR 13.12.1 The following Halon systems shall be FUNCTIONAL.

a.

Train A Remote Shutdown Panel Room, Zone 10A - Control Building 100 ft Elevation.

b.

Train B Remote Shutdown Panel Room, Zone 10B - Control Building 100 ft. Elevation.

APPLICABILITY:

Whenever equipment protected by the Halon system is required to be OPERABLE or FUNCTIONAL.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more of the required Halon systems nonfunctional in areas in which redundant systems or components could be damaged.

A.1 Establish a continuous fire watch with backup fire suppression equipment.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B. One or more of the required Halon systems nonfunctional in areas other than those in which redundant systems or components could be damaged.

B.1 Establish an hourly fire watch patrol.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

Halon Systems 13.12.1

[Station Name]

13.12.1-2 Revision ##

[Unit #]

TECHNICAL REQUIREMENT SURVEILLANCES SURVEILLANCE FREQUENCY TRS 13.12.1.1 For each of the required Halon systems, verify that each valve (manual, power operated, or automatic) in the flow path is in its correct position.

31 days TRS 13.12.1.2 For each of the required Halon systems, verify Halon storage tank weight or level to be at least 95% of full charge weight or level and pressure to be at least 90% of full charge pressure.

6 months TRS 13.12.1.3 For each of the required Halon systems, verify the system actuates manually and automatically, upon receipt of a simulated test signal.

18 months SUPPORT FUNCTION The halon systems do not support any TS function.

BASES The fire suppression systems ensure that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility that contains equipment that is required to be OPERABLE by the plant TS or FUNCTIONAL by the plant TRM.

DESIGN FEATURES 14.0

[Station Name]

14-1 Revision ##

[Unit #]

14 DESIGN FEATURES Not used.

ADMINISTRATIVE CONTROLS 15.0

[Station Name]

15.1-1 Revision ##

[Unit #]

15 ADMINISTRATIVE CONTROLS 15.1 Site Fire Brigade A site fire brigade of at least 5 members shall be maintained onsite at all times. The fire brigade shall not include members of the minimum shift crew necessary for safe shutdown of the unit or any personnel required for other essential functions during a fire emergency.

The composition of the fire brigade may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

OPERATIONAL REFERENCES 16.0

[Station Name]

16.1-1 Revision ##

[Unit #]

16.0 OPERATIONAL REFERENCES 16.1 Containment Isolation Valves

REFERENCE:

Table 16.1-1 is applicable to TS 3.6.3, "Containment Isolation Valves."

Table 16.1-1 (page 1 of 1)

Containment Isolation Valves VALVE NUMBER (SEC)

FUNCTION ISOLATION TIME (SEC)

1.

Q1/2G31V012 Refueling Cavity Supply N/A

2.

Q1/2G21V005 Reactor Coolant Drain Tank N/A

3.

RHR-MOV-8701A Reactor Coolant LP C to RHR Pump A

< 120

4.

RHR-MOV-8702A Reactor Coolant LP A to RHR Pump B

< 120

5.

Q1/2P18V001 Service Air N/A

6.

Q1/2P18V002 Service Air N/A

7.

CBV-MOV-3238 CTMT Leak Rate Test Valve N/A

8.

CBV-MOV-3239 CTMT Leak Rate Test Valve N/A

9.

RHR-MOV-8811A CTMT Sump to RHR Pump A

< 17

10.

RHR-MOV-8811B CTMT Sump to RHR Pump B

< 17

11.

RHR-MOV-8812A CTMT Sump to RHR Pump A

< 17

12.

RHR-MOV-8812B CTMT Sump to RHR Pump B

< 17

13.

CS-MOV-8826A CS Pump A CTMT Sump Suction Iso.

< 17

14.

CS-MOV-8826B CS Pump B CTMT Sump Suction Iso.

< 17

15.

CS-MOV-8827A CS Pump A CTMT Sump Suction Iso.

< 17

16.

CS-MOV-8827B CS Pump B CTMT Sump Suction Iso.

< 17

17.

Q1/2B13V026B Pressurizer Pressure Generator N/A

18.

CBV-MOV-3528A CTMT Post-LOCA Sampling Valve 1 N/A

19.

CBV-MOV-3528B CTMT Post-LOCA Sampling Valve 2 N/A

20.

CBV-MOV-3528C CTMT Post-LOCA Sampling Valve 3 N/A

TSTF-GG-21-01, Rev. 0 April 2021 B-1 Appendix B Example Applicability Determinations Contents

1. Completion Time Maintenance Rule Backstop

2. Revision to the TRS Applicability Requirements

3. Elimination of Shut Down Actions and Substitution of a Condition Report

4. Elimination of Mode Change Restrictions

5. Elimination of NRC Reporting Requirements

6. Elimination of Required Actions to Declare TS Systems Inoperable

TSTF-GG-21-01, Rev. 0 April 2021 B-2 B.1 Completion Time Maintenance Rule Backstop Description The following TR Required Actions specify that a nonfunctional SSC must be restored to functional status within a specified Completion Time:

[Note: List the plant-specific Required Actions here. The following are examples.

TR 13.1.1, "Boration Systems - Operating," Required Action A.1 TR 13.3.2, "Seismic Monitoring Instrumentation," Required Action A.1 TR 13.6.1, "Hydrogen Recombiners," Required Actions A.1 and B.1]

The Required Actions are modified to have two Completion Times: The existing fixed Completion Time (referred to as the "front stop"), and an optional Completion Time based on the licensee-established performance goals required by 10 CFR 50.65(a)(4) (referred to in this guidance as the "Maintenance Rule backstop"). The latter is stated as "OR In accordance with the Maintenance Rule." The front stop Completion Time may always be used. Use of the Maintenance Rule backstop is elective and may be used after the front stop Completion Time is in use or has been exceeded.

If desired, a licensee could eliminate front stop Completion Times and use only the Maintenance Rule Completion Times. A licensee could extend a front stop Completion Time using the justification below.

Applicability Determination Unavailability of equipment is addressed in 10 CFR 50.65(a)(4). The Maintenance Rule requires that licensees "... monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken."

Licensees have flexibility in establishing Maintenance Rule performance criteria and not all performance criteria are time-based. In that case, the Maintenance Rule backstop option could be included in the TRM as a future provision but could not be used. However, if the performance criteria are time-based (for example, a goal of maintaining 95 percent availability), a time limit for the system to be nonfunctional could be established and used in lieu of a fixed "front stop" Completion Time.

The primary purpose of Completion Time is to manage risk associated with equipment that is out of service. However, 10 CFR 50.65(a)(4), the Maintenance Rule, specifically addresses the management the risk associated with unavailable equipment. Therefore,

TSTF-GG-21-01, Rev. 0 April 2021 B-3 consistent with 10 CFR 50.59(c)(4), the Maintenance Rule is the more applicable regulation to establish specific criteria for accomplishing the proposed change.

TSTF-GG-21-01, Rev. 0 April 2021 B-4 B.2 Revision to the TRS Applicability Requirements Description The existing TRM equivalent requirement to STS SR 3.0.2 states that the specified Frequency for each TRS is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency. If the TRS is not performed within the specified Frequency, the associated TR is not met. In the example TRM, TRS 13.0.2 states that if a TRS is not performed within the specified Frequency, a Condition Report shall be initiated to determine if the associated TR is met.

The existing TRM equivalent requirement to STS SR 3.0.3 states that if it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the TR not met may be delayed up to the limit of the specified Frequency. There is no equivalent in the example TRM.

It is important to note that the use of "met" or "performed" conveys specific meanings. A TRS is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a TRS, even without a TRS specifically being "performed," constitutes a TRS not "met" and under TRS 13.0.1, the associated TR is not met. "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria.

Applicability Determination In the TRM, the equivalent of STS SR 3.0.2 and STS SR 3.0.3 are administrative controls, similar to other administrative controls in procedures like "hold points." Therefore, a licensee may eliminate or revise the existing TRM equivalents as an administrative change to the TRM, and the more specific regulation is 10 CFR 50, Appendix B, as implemented by the licensee's quality assurance program.

TSTF-GG-21-01, Rev. 0 April 2021 B-5 B.3 Elimination of Shut Down Actions Description The proposed change eliminates TRM Actions to require a plant shutdown. Instead, the TRM requires creation of a Condition Report in accordance with the Corrective Action Program to determine the appropriate actions. This change is also made to TR 13.0.3, which is the applicable requirement if a TR's ACTIONS are not met or if there is no ACTION provided.

[Note: List the plant-specific Required Actions that direct a plant shutdown. The following is an example.

TR Required Action 3.8.4.A.1]

As an alternative to requiring creation of a Condition Report, the TRM Action can be deleted. If no TR ACTION is applicable, TR 13.0.3 applies, which requires creating a Condition Report. The justification below is applicable.

Applicability Determination The proposed activity replaces Required Actions to shut down the unit with Required Actions to create a Condition Report in accordance with the Corrective Action Program to determine the appropriate actions. Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2) states that if a limiting condition for operation is not met, a plant shutdown or any other action specified in the TS should be followed. The requirements in the TRM have been determined to not meet any of the criteria in 10 CFR 50.36(c)(2)(ii) for inclusion in the Technical Specifications or have been otherwise determined by the NRC to not be appropriate for inclusion in the Technical Specifications (e.g., Generic Letter 91-08, "Removal of Component Lists from Technical Specifications", Generic Letter 88-12, "Removal of Fire Protection Requirements from Technical Specifications"). There is no regulatory requirement for a plant shutdown due to not meeting a TRM condition.

The TRM Required Actions are actions to address a TR that is not met. As such, the Required Actions fall under the Appendix B Corrective Action Program. As discussed in NEI 96-07, Section 4.4, "If the licensee intends to restore the SSC back to its as-designed condition then this corrective action should be performed in accordance with 10 CFR 50, Appendix B (i.e., in a timely manner commensurate with safety). This activity is not subject to review under 10 CFR 50.59." Therefore, replacing the existing shutdown requirements with a requirement to create a Condition Report under the Corrective Action Program is subject to Criterion XVI of 10 CFR 50, Appendix B, which is the appropriate change process, and the proposed change is not subject to review under 10 CFR 50.59.

Should a decision be made under the Corrective Action Program to not restore the degraded or nonconforming condition back to the as-designed condition, that decision may require review under 10 CFR 50.59.

TSTF-GG-21-01, Rev. 0 April 2021 B-6 The primary purpose of requiring a plant shutdown due to failure to meet a TRM requirement is to manage risk associated with nonfunctional equipment. However, 10 CFR 50.65(a)(4), the Maintenance Rule, specifically addresses the management of the risk associated with unavailable equipment. Therefore, consistent with 10 CFR 50.59(c)(4), the Maintenance Rule is the more applicable regulation to establish specific criteria for accomplishing the proposed change.

Should the failure to meet a TRM requirement result in TS requirements not being met, the TS Required Actions, including a plant shutdown, may apply.

TSTF-GG-21-01, Rev. 0 April 2021 B-7 B.4 Elimination of Mode Change Restrictions Description STS LCO 3.0.4 prohibits entering the Mode or other specified condition in the Applicability when the LCO is not met, unless LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c applies. LCO 3.0.4.b permits entering Modes with the LCO not met if risk is assessed and managed with some exceptions. STS SR 3.0.4 prohibits entry into a Mode or other specified condition in the Applicability if the LCO's Surveillance Requirements are not met, except as permitted by LCO 3.0.4.

The example TRM does not include an equivalent to STS LCO 3.0.4 or STS SR 3.0.4 and there is no restriction on entering a Mode or other condition in the Applicability with a TR or TRS not met. However, if a Mode or other specified condition in the Applicability is entered with a TR not met, the associated ACTIONS must be followed. If a Mode or other specified condition in the Applicability is entered with a TRS not met, SR 3.0.2 requires that a Condition Report be initiated to determine if the associated TR is met.

Applicability Determination In the TRM, the equivalent of STS LCO 3.0.4 and SR 3.0.4 are administrative controls, similar to other administrative controls in procedures like "hold points." Therefore, a licensee may eliminate or revise the existing TRM equivalents as an administrative change to the TRM, and the more specific regulation is 10 CFR 50, Appendix B, as implemented by the licensee's quality assurance program.

TSTF-GG-21-01, Rev. 0 April 2021 B-8 B.5 Elimination of NRC Reporting Requirements Description The TRM retained requirements to send reports to the Nuclear Regulatory Commission (NRC) that were in the plant TS. The proposed change eliminates the TRM requirements to submit reports to the NRC. There is no regulatory basis for submitting reports to the NRC that are not required by the regulations, the license, or the TS. Specifically:

[List plant-specific NRC reports. For example, the "Startup Report," "Annual Specific Activity Report," "Special Reports," and "ECCS System Actuations."]

Applicability Determination NRC Office of Nuclear Reactor Regulation Office Instruction LIC-100, Revision 1, "Control of Licensing Bases for Operating Reactors", Section 3.1.2, "Technical Requirements Manual," states, "Note that some of the relocated TS provisions included special reporting requirements. The determination that the reports were not required was inherent in the staffs findings that the provisions could be relocated."

Therefore, the alternative, more specific regulation for the change is 10 CFR 50.90, because relocation and elimination of the need to submit the reports was authorized in the license amendment that relocated the reporting requirement.

TSTF-GG-21-01, Rev. 0 April 2021 B-9 B.6 Elimination of Required Actions to Declare TS Systems Inoperable Description The following TRM Required Actions direct declaring a TS SSC inoperable. The Required Actions are proposed to be removed from the TRM. The revised TRM requirement is to create a Condition Report in accordance with the Corrective Action Program.

[Note: List the affected TRM Required Actions.]

Applicability Determination The TRM requirement to declare a TS system inoperable is duplicative of the 10 CFR 50.36 requirement for a licensee to have and follow the TS. The TS contain a definition and descriptions (LCOs, Surveillances, and Bases) that provide sufficient guidance to implement the TS requirement for systems to be operable. Therefore, the TRM Required Actions to declare a TS SSC inoperable are unnecessary and duplicative of the TS requirements and do not alter the TS definition of operability or its application to an SSC. This change is an administrative change to the TRM and the more specific regulation is 10 CFR 50, Appendix B, as implemented by the licensee's quality assurance program.

TSTF-21-02, Submittal for Information of TSTF-GG-21-01, Technical Requirements Manual and Operational References (TRM) Format and Content Guideline

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SUBJECT:

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