JAFP-23-0065, License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications

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License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications
ML23348A154
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/14/2023
From: David Gudger
Constellation Energy Company
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-23-0065
Download: ML23348A154 (1)


Text

200 Exelon Way Kennett Square, PA 19348

www.exeloncorp.com

10 CFR 50.90

JAFP-23-0065

December 14, 2023

United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4, and Administrative Changes to the Technical Specifications

In accordance with the provisions of Title 10 of the Code of Federal Regulations of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit,"

Constellation Energy Generation, LLC (CEG) is submitting a license amendment request (LAR) to revise Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendment would modify TS requirements in Section 1.3 regarding Completion Times and Section 3.0 regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with the Nuclear Regulatory Commission (NRC) approved Technical Specifications Task Force (TSTF)

Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4.

Additionally, the proposed amendment makes several administrative changes to the JAF TS.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations.

provides the proposed changes. Attachment 2 provides the existing JAF TS Marked-Up pages to show the proposed changes. Attachment 3 provides the JAF TS clean pages of the proposed changes. Attachment 4 provides the TS Bases pages marked up to show the associated TS Bases changes and are provided for information only.

There are no new regulatory commitments contained in this submittal.

U.S. Nuclear Regulatory Commission License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," and Administrative Changes to the Technical Specifications December 14, 2023 Page 2

CEG requests approval of the proposed amendment by December 14, 2024. Once approved, the amendment shall be implemented within 60 days of issuance.

The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

Should you have any questions concerning this submittal, please contact Abul Hasanat Abul.Hasanat@Constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day December 2023.

Respectfully,

David T. Gudger Senior Manager - Licensing & Regulatory Affairs Constellation Energy Generation, LLC

Attachments:

1. Evaluation of Proposed Changes
2. Proposed Technical Specification Marked-Up Pages
3. Proposed Technical Specification Clean Pages
4. Proposed Technical Specification Bases Marked-Up Pages (for information only)

cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, JAF w/attachments USNRC Project Manager, JAF w/attachments A. L. Peterson, NYSERDA w/attachments

ATTACHMENT 1

James A. FitzPatrick Nuclear Power Plant

Docket No. 50-333

EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4, and Administrative Changes to the Technical Specifications

1.0

SUMMARY

DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Variations

3.0 DETAILED DESCRIPTION

4.0 TECHNICAL EVALUATION

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria 5.2 No Significant Hazards Consideration

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules," Page 2 of 9 Docket No. 50-333 Evaluation of Proposed Changes

1.0

SUMMARY

DESCRIPTION

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) is submitting a license amendment request (LAR) to revise Technical Specifications (TS) for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes revise Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the TS to clarify the use and application of the TS usage rules, as described below:

  • Section 1.3 is revised to clarify "discovery."
  • Section 1.3 is revised to discuss exceptions to be starting the Completion Time at condition entry.

The proposed amendment also makes several administrative changes to the JAF TS.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation

CEG has reviewed the safety evaluation for TSTF -529 provided to the TS Task Force in a letter dated April 21, 2016. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-529. CEG has concluded that the justifications presented in TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to JAF and justify this amendment for the incorporation of the changes to plants TS.

2.2 Variations

For JAF, CEG is not proposing any variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staff's safety evaluation dated April 21, 2016.

3.0 DETAILED DESCRIPTION

The following is a detailed description, by TS page number, of each proposed administrative change:

TS Page 3.3.3.2-2

SR 3.3.3.2.1, under FREQUENCY, by Program, deleted "*"

SR Corrected from to 3.6.4.1 to 3.3.3.2 Deleted footnote,

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 3 of 9 Docket No. 50-333 Evaluation of Proposed Changes

  • This Surveillance for ST-43I is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.3.6.1-4

SR 3.3.6.1.2, under FREQUENCY, by Program, deleted

  • Deleted footnote,
  • This Surveillance for ISP-150B is not required to be performed for functions 4.a, 4.b, 4.d, 4.e and 4.f of table 3.3.6.1-1 until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.3.6.1-5

SR 3.3.6.1.5, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for ISP-150B is not required to be performed for functions 4.a, 4.b, 4.d, 4.e and 4.f of table 3.3.6.1-1 until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Pages 3.5.1-1

Under Completion Time, by 7 days, deleted "*"

Deleted footnote,

  • The Completion Time to return the "A" RHR pump to OPERALE is extended to 34 days, contingent on implementation of Compensatory Actions stated in Section 3.4 of letter JAFP-21 0053, dated June 14, 2021, as a one-time only change ending upon restoration the "A" RHR pump to OPERABLE, or on July 11, 2021 at 20:00 hours.

TS Pages 3.5.1-4

SR 3.5.1.1 and 3.5.1.2, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for ST-4B is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 4 of 9 Docket No. 50-333 Evaluation of Proposed Changes

TS Page 3.5.3-1

On the Header, top right corner, changed from RCIC SYSTEM to RCIC System

TS Page 3.5.3-2

On the Header, top right corner, changed from RCIC SYSTEM to RCIC System SR 3.5.3.1, 3.5.3.2, 3.5.3.3 and 3.5.3.4 under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for ST-24J is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.5.3-3

On the Header, top right corner, changed from RCIC SYSTEM to RCIC System

TS Page 3.6.1.3-8

SR 3.6.1.3.5, under FREQUENCY, by PROGRAM, deleted "*"

Deleted footnote,

  • This Surveillance for ST-24J is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.6.4.1-1

Under Condition A, COMPLETION TIME, by 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, deleted "*"

Deleted footnote,

  • The Completion Time is extended to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, in support of the "A" RHR pump repairs, contingent on implementation of Compensatory Actions stated in Section 3.4 of letter JAFP 0053, dated June 14, 2021, as a one-time only change ending upon restoration of the "A" RHR pump to OPERABLE, or on July 11, 2021 at 20:00 hours. Multiple entries may be necessary to implement compensatory actions, or to address unforeseen circumsta nces related to the "A" RHR pump motor replacement.

TS Page 3.7.4-3

SR 3.7.4.1, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 5 of 9 Docket No. 50-333 Evaluation of Proposed Changes

  • This Surveillance ST-8Q is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Pages 3.8.1-5

SR 3.8.1.2, under FREQUENCY, by Program, deleted "*"

SR 3.8.1.3, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • The Surveillances for ST-9BA and ST-9BB is not required to be performed until following the return of the "A" RHR Pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Pages 3.8.1-6

SR 3.8.1.4, under FREQUENCY, by Program, deleted "*"

SR 3.8.1.5, under FREQUENCY, by Program, deleted "*"

SR 3.8.1.6, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • The Surveillances for ST-9AA, ST-9BB, ST-9BA, and ST-9BA is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Pages 3.8.3-2

SR 3.8.3.1 under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for ST-9AA and ST-9BB is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Pages 3.8.3-3

SR 3.8.3.2, under FREQUENCY, by Program, deleted "*"

SR 3.8.3.4, under FREQUENCY, by Program, deleted "*"

SR 3.8.3.5, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for ST-9AA and ST-9BB is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 6 of 9 Docket No. 50-333 Evaluation of Proposed Changes

TS Page 3.8.4-3

SR 3.8.4.1, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for MST-071.10 is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.8.5-2

SR 3.8.5.1, under FREQUENCY, by SRs, deleted "*"

Deleted footnote,

  • This Surveillance for MST-071.12 is not required to be performed following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.8.6-2

SR 3.8.6.1, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for MST-071.11 and MST-071.13 is not required to be performed until following the return of the "A" RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

TS Page 3.8.6-3

SR 3.8.6.2, under FREQUENCY, by Program, deleted "*"

SR 3.8.6.3, under FREQUENCY, by Program, deleted "*"

Deleted footnote,

  • This Surveillance for MST-071.11 and MST-071.13 is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

4.0 TECHNICAL EVALUATION

The proposed changes described in Section 3 above removed the expired information inserted by TS Amendment 342 into the JAF TS (Reference 3). These changes also corrects formatting.

The proposed changes do not adversely alter the current TS or introduce any new TS requirements. When implemented, these changes will provide continuity and consistency throughout the JAF TS. No further technical evaluation is needed to justify these changes.

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 7 of 9 Docket No. 50-333 Evaluation of Proposed Changes

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria

Title 10 Code of Federal Regulations 50.36, "Technical Specifications".

5.2 No Significant Hazards Determination

CEG requests adoption of TSTF-529, "Clarify Use and Application Rules," Revision 4 for JAF.

The NRC approved the TSTF-529.

The proposed changes revise Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the TS to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

CEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to TS Section 1.3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes do not significantly affect system Operability, the proposed changes will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Additionally, the proposed amendment makes several administrative changes to the JAF TS.

Therefore, it is concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

These changes do not alter the design or configuration of the plant. The proposed changes do not involve a physical alteration of the plant and no new or different kind of equipment will

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 8 of 9 Docket No. 50-333 Evaluation of Proposed Changes

be installed. The proposed changes are administrative in nature. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Additionally, the proposed amendment makes several administrative changes to the JAF TS.

Therefore, it is concluded that the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed changes clarify the application of Section 1.3 and LCO 3.0.4 and do not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Additionally, the proposed amendment makes several administrative changes to the JAF TS.

Therefore, it is concluded that the changes do not involve a significant reduction in a margin of safety.

Based on the above, CEG concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or SR. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

License Amendment Request to Revise Technical Specifications Attachment 1 to Adopt TSTF-529, "Clarify Use and Application Rules" Page 9 of 9 Docket No. 50-333 Evaluation of Proposed Changes

7.0 REFERENCES

1. TSTF-529, Revision 4, "Clarify Use and Application Rules," dated April 25, 2016.
2. Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-529, Revision 4, "Clarify Use and Application Rules" using the Consolidated Line Item Improvement Process (TAC Nos. MF1406 and MF1407) ADAMS Accession Nos.

ML16060A455 (Letter/Public); ML16060A440 (Final SE/Public); ML16060A441 (Package/Public).

3. James A. Fitzpatrick Nuclear Power Plant - Correction to Amendment No 342 Issued June 14, 2021, Re: One Time Extension to Technical Specifications 3.5.1, 3.6.1.9, and 3.6.4.1 Completion Times to Support Residual Heat Removal Pump Motor Replacement (Emergency Circumstances) (EPID L-2021-LLA-0110). ML21166A366.

ATTACHMENT 2

License Amendment Request

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333

PROPOSED TECHNICAL SPECIFICATION MARKED-UP PAGES

1.3-1 1.3-2 3.0-2 3.0-5 3.3.3.2-2 3.3.6.1-4 3.3.6.1-5 3.5.1-1 3.5.1-4 3.5.3-1 3.5.3-2 3.5.3-3 3.6.1.3-8 3.6.4.1-1 3.7.4-3 3.8.1-5 3.8.1-6 3.8.3-2 3.8.3-3 3.8.4-3 3.8.5-2 3.8.6-2 3.8.6-3

Completion Times 1.3

1.0 USE AND APPLICATION

1.3 Completion Times

PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operat ion (LCOs) specify minimum requirements for ensuring safe operation of the plant. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the am ount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the plant is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the plant is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the (continued)

JAFNPP 1.3-1 Amendment Completion Times 1.3

1.3 Completion Times

DESCRIPTION Required Actions for each Condition must be performed within the (continued) associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and
b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time (continued)

JAFNPP 1.3-2 Amendment LCO Applicability 3.0

3.0 LCO APPLICABILITY

LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) 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;( exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

JAFNPP 3.0-2 Amendment SR Applicability 3.0

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY

SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Fr equency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance 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.

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.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 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, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

JAFNPP 3.0-5 Amendment Remote Shutdown System 3.3.3.2

SURVEILLANCE REQUIREMENTS


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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

SURVEILLANCE FREQUENCY

SR 3.3.3.2.1 Perform CHANNEL CHECK for each required In accordance instrumentation channel that is normally with the energized. Sur veillance Frequency Control Program*

SR 3.3.3.2.2 Verify each required control circuit and transfer In accordance switch is capable of performing the intended with the function. Sur veillance Frequency Control Program

SR 3.63.43.12. Perform CHANEL CALIBRATION for each required In accordance instrumentation channel. with the Sur veillance Frequency Control Program

  • This Surveillance for ST-43I is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.3.3.2-2 Amendment Primary Containment Isolation Instrumentation 3.3.6.1

SURVEILLANCE REQUIREMENTS


NOTES----------------------------------------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2.d, 2.g, 7.a, and 7.b; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 2.d, 2.g, 7.a, and 7.b provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY

SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Sur veillance Frequency Control Program*

SR 3.3.6.1.3 ----------------- ------NOTE------- ---------------

For Functions 1.f and 2.f, radiation detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Sur veillance Frequency Control Program

(continued)

  • This Surveillance for ISP-150B is not required to be performed for functions 4.a, 4.b, 4.d, 4.e and 4.f of table 3.3.6.1-1 until following the return of the A RHR pump to OPERABLE.

This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.3.6.1-4 Amendment Primary Containment Isolation Instrumentation 3.3.6.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.3.6.1.4 Calibrate the trip units. In accordance with the Sur veillance Frequency Control Program*

SR 3.3.6.1.5 Perform CHANNEL CALIBRATION. In accordance with the Sur veillance Frequency Control Program*

SR 3.3.6.1.6 Calibrate the radiation detectors. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Sur veillance Frequency Control Program

  • This Surveillance for ISP-150B is not required to be performed for functions 4.a, 4.b, 4.d, 4.e and 4.f of table 3.3.6.1-1 until following the return of the A RHR pump to OPERABLE.

This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.3.6.1-5 Amendment ECCS - Operating 3.5.1

3.5 EMERGENCY CORE COOLING SYSTEMS (E CCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.


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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS


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

LCO 3.0.4.b is not applicable to High Pressure Coolant Injection (HPCI).

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days*

injection/spray ECCS injection/spray OR subsystem inop erable. subsystem(s) to OR OPERABLE status. In accordance with One low pressure coolant the Risk Informed injection (LPCI) pump in Completion Time both LPCI subsystems Program inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion AND Time of Condition A not B.2 Be in Mode 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> met.

(continued)

  • The Completion Time to return the A RHR pump to OPERALE is extended to 34 days, contingent on implementation of Compensatory Actions stated in Section 3.4 of letter JAFP-21-0053, dated June 14, 2021, as a one-time only change ending upon restoration the A RHR pump to OPERABLE, or on July 11, 2021 at 20:00 hours.

JAFNPP 3.5.1-1 Amendment ECCS - Operating 3.5.1

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, In accordance the piping is filled with water from the pump with the discharge valve to the injection valve. Sur veillance Frequency Control Program*

SR 3.5.1.2 Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve in with the the flow path, that is not locked, sealed, or Sur veillance otherwise secured in position, is in the correct Frequency Control position. Program*

SR 3.5.1.3 Verify ADS pneumatic supply header pressure is In accordance 95 psig. with the Sur veillance Frequency Control Program

SR 3.5.1.4 Verify the RHR System cross tie valves are closed In accordance and power is removed from the electrical valve with the operator. Sur veillance Frequency Control Program

SR 3.5.1.5 Cycle open and closed each LPCI motor operated In accordance valve independent power supply battery charger with the AC input breaker and verify each LPCI inverter Sur veillance output voltage is 576 V and 624 V while Frequency Control supplying the respective bus. Program

(continued)

  • This Surveillance for ST-4B is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.5.1-4 Amendment RCIC SystemYSTEM 3.5.3

3.5 EMERGENCY CORE COOLING SYSTEMS (E CCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System

LCO 3.5.3 The RCIC System shall be OPERABLE

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS


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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME

A. RCIC System A.1 Verify by administrative Immediately inoperable. means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status. OR

In accordance with the Risk Informed Completion Time Program

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND

B.2 Reduce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure to 150 psig.

JAFNPP 3.5.3-1 Amendment RCIC SystemYSTEM 3.5.3

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.5.3.1 Verify the RCIC System piping is filled with water In accordance from the pump discharge valve to the injection with the valve. Sur veillance Frequency Control Program*

SR 3.5.3.2 Verify each RCIC System manual, power operated, In accordance and automatic valve in the flow path, that is not with the locked, sealed, or otherwise secured in position, is Sur veillance in the correct position. Frequency Control Program*

SR 3.5.3.3 ----------------- ------NOTE------- ---------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1040 psig and In accordance 970 psig, the RCIC pump can develop a flow rate with the 400 gpm against a system head corresponding Sur veillance to reactor pressure. Frequency Control Program*

SR 3.5.3.4 ----------------- ------NOTE------- ---------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 165 psig, the RCIC In accordance pump can develop a flow rate 400 gpm against with the a system head corresponding to reactor pressure. Sur veillance Frequency Control Program*

(continued)

  • This Surveillance for ST-24J is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.5.3-2 Amendment RCIC SystemYSTEM 3.5.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.5.3.5 ----------------- ------NOTE------- ---------------

1. Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
2. Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or In accordance simulated automatic initiation signal, except for with the valves that are locked, sealed, or otherwise Surveillance secured in the actuated position. Frequency Control Program

JAFNPP 3.5.3-3 Amendment PCIVs 3.6.1.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.6.1.3.3 ----------------- ------NOTES------ ---------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation Prior to entering valve and blind flange that is located inside MODE 2 or 3 from primary containment and not locked, sealed or MODE 4 if otherwise secured and is required to be closed primar y during accident conditions is closed. containment was de-iner ted while in MODE 4, if not per formed within the previous 92 days

SR 3.6.1.3.4 Verify continuity of the traversing incore probe In accordance (TIP) shear isolation valve explosive charge. with the Sur veillance Frequency Control Program

SR 3.6.1.3.5 Verify the isolation time of each power operated, In accordance automatic PCIV, except for MSIVs, is within limits. with the INSERVICE TESTING PROGRAM*

SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 In accordance seconds and 5 seconds. with the INSERVICE TESTING PROGRAM

(continued)

  • This Surveillance for ST-24J is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.6.1.3-8 Amendment Secondary Containment 3.6.4.1

3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment

LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. Secondary containment A.1 Restore secondary 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s*

inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not AND met. B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

C. Secondary containment C.1 ---------NOTE---------

inoperable during LCO 3.0.3 is not movement of recently applicable.

irradiated fuel -----------------------

assemblies in the secondary containment. Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

  • The Completion Time is extended to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, in support of the A RHR pump repairs, contingent on implementation of Compensatory Actions stated in Section 3.4 of letter JAFP-21-0053, dated June 14, 2021, as a one-time on ly change ending upon restoration of the A RHR pump to OPERABLE, or on July 11, 2021 at 20:00 hours. Multiple entries may be necessary to implement compensatory actions, or to address unforeseen circumstances related to the A RHR pump motor replacement.

JAFNPP 3.6.4.1-1 Amendment Control Room AC System 3.7.4

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.7.4.1 Verify each control room AC subsystem has the In accordance capability to remove the assumed heat load. with the Sur veillance Frequency Control Program*

  • This Surveillance ST-8Q is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.7.4-3 Amendment AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.2 ----------------- ------NOTE------- ---------------

All EDG subsystem starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each EDG subsystem starts from standby In accordance conditions, force parallels, and achieves: with the

a. In 10 seconds, voltage 3900 V and Sur veillance frequency 58.8 Hz; and Frequency Control Program*
b. Steady state voltage 3900 V and 4400 V and frequency 58.8 Hz and 61.2 Hz.

SR 3.8.1.3 ----------------- ------NOTE------- ---------------

1. EDG loading may include gradual loading as recommended by the manufacturer.
2. Momentary transients outside the load range do not invalidate this test.
3. This Surveillance shall be conducted on only one EDG subsystem at a time.
4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.

Verify each EDG subsystem is paralleled with In accordance normal, reserve, or backfeed power and each EDG with the is loaded and operates for 60 minutes at a load Sur veillance 2340 kW and 2600 kW. Frequency Control Program*

(continued)

  • The Surveillances for ST-9BA and ST-9BB is not required to be performed until following the return of the A RHR Pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of lette r JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.1-5 Amendment AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.4 Verify each day tank contains 327 gal of fuel oil. In accordance with the Sur veillance Frequency Control Program*

SR 3.8.1.5 Check for and remove accumulated water from each In accordance with day tank the Sur veillance Frequency Control Program*

SR 3.8.1.6 Verify that each EDG fuel oil transfer system In accordance with operates to automatically transfer fuel oil from its the Sur veillance storage tank to the associated day tank. Frequency Control Program*

SR 3.8.1.7 ----------------- ------NOTE------- ----------------- Only required to be met for each offsite circuit that is not energizing its respective 4.16 kV emergency bus.


----------------------------------- In accordance with Verify automatic and manual transfer of plant power the Sur veillance supply from the normal station service transformer Frequency Control to each offsite circuit. Program

SR 3.8.1.8 ----------------- ------NOTE------- ----------------- If performance with EDG subsystem paralleled with normal, reserve, or backfeed power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.

Verify each EDG subsystem rejects a load greater In accordance with than or equal to its associated single largest post-the Sur veillance accident load, and following load rejection, the Frequency Control frequency is 66.75 Hz. Program (continued)

  • The Surveillances for ST-9AA, ST-9BB, ST-9BA, and ST-9BA is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.1-6 Amendment Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. One or more EDGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limit.

not within limits.

E. One or more EDGs with E.1 Restore required starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> required starting air air receiver pressure to receiver pressure < within limits.

150 psig and 110 psig.

F. Requires Action and F.1 Declare associated EDG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR

One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other then condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.8.3.1 Verify each fuel oil storage tank contains a 7 day In accordance supply of fuel. with the Surveillance Frequency Control Program*

(continued)

  • This Surveillance for ST-9AA and ST-9BB is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.3-2 Amendment Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.3.2 Verify lube oil inventory of each EDG is a 7 day In accordance supply. with the Sur veillance Frequency Control Program*

SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained with the Diesel within the limits of, the diesel Fuel Oil Testing Fuel Oil Testing Program. Program

SR 3.8.3.4 Verify Each EDG required air start receiver pressure In accordance is 150 psig. with the Sur veillance Frequency Control Program*

SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Sur veillance Frequency Control Program*

  • This Surveillance for ST-9AA and ST-9BB is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.3-3 Amendment DC Sources - Operating 3.8.4

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.4.1 Verify battery terminal voltage on float charge is: In accordance

a. 127.8 VDC for 125 VDC batteries, and with the Sur veillance
b. 396.2 VDC for 419 VDC LPCI MOV Frequency Control independent power supply batteries. Program*

SR 3.8.4.2 Verify each 125 VDC battery charger supplies In accordance 270 amps at 128 VDC for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. with the Sur veillance OR Frequency Control Verify each 125 VDC battery charger can recharge Program

the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

SR 3.8.4.3 ----------------- ------NOTE------- ---------------

This Surveillance shall not normally be performed in MODE 1, 2, or 3 for the 125 VDC batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance maintain in OPERABLE status, the required with the emergency loads for the design duty cycle when Sur veillance subjected to a battery service test or a modified Frequency Control performance discharge test. Program

(continued)

  • This Surveillance for MST-071.10 is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.4-3 Amendment DC Sources - Shutdown 3.8.5

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2.3 Initiate action to Immediately restore required DC electrical power subsystem to OPERABLE status.

SURVEILLANCE REQUREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.5.1 ----------------- ------NOTE------- ---------------

The following SRs are not required to be performed: SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.

For DC electrical power subsystem required to In accordance be OPERABLE the fallowing SRs are applicable: with applicable SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SRs*

SR 3.8.4.4.

  • This Surveillance for MST-071.12 is not required to be performed following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.5-2 Amendment Battery Cell Parameters 3.8.6

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1.

B. Required Action and B.1 Declare associated Immediately associated battery inoperable.

Completion Time of Condition A not met.

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

OR One or more batteries with one or more battery cell parameters not within Category C limits.

SURVEILLANCE REQUREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits. In accordance with the Sur veillance Frequency Control Program*

(continued)

  • This Surveillance for MST-071.11 and MST-071.13 is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.6-2 Amendment Battery Cell Parameters 3.8.6

SURVEILLANCE REQUREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 In accordance Category B limits. with the Surveillance Frequency Control Program*

SR 3.8.6.2 Verify average electrolyte temperature of In accordance representative cells is 65°F for each 125 VDC with the battery, and 50°F for each 419 VDC LPCI MOV Surveillance independent power supply battery. Frequency Control Program*

  • This Surveillance for MST-071.11 and MST-071.13 is not required to be performed until following the return of the A RHR pump to OPERABLE. This past due Surveillance will be completed as stated in Section 3.5 of letter JAFP-21-0053, dated June 14, 2021.

JAFNPP 3.8.6-3 Amendment ATTACHMENT 3

License Amendment Request

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333

PROPOSED TECHNICAL SPECIFICATION CLEAN PAGES

1.3-1 1.3-2 3.0-2 3.0-5 3.3.3.2-2 3.3.6.1-4 3.3.6.1-5 3.5.1-1 3.5.1-4 3.5.3-1 3.5.3-2 3.5.3-3 3.6.1.3-8 3.6.4.1-1 3.7.4-3 3.8.1-5 3.8.1-6 3.8.3-2 3.8.3-3 3.8.4-3 3.8.5-2 3.8.6-2 3.8.6-3

Completion Times 1.3

1.0 USE AND APPLICATION

1.3 Completion Times

PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operat ion (LCOs) specify minimum requirements for ensuring safe operation of the plant. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the am ount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,

inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the plant is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the plant is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the (continued)

JAFNPP 1.3-1 Amendment Completion Times 1.3

1.3 Completion Times

DESCRIPTION associated Completion Time. When in multiple Conditions, separate (continued) Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and
b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..." (continued)

JAFNPP 1.3-2 Amendment LCO Applicability 3.0

3.0 LCO APPLICABILITY

LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) 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 (exceptions to this Specification are stated in the individual Specifications) or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

JAFNPP 3.0-2 Amendment SR Applicability 3.0

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY

SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Fr equency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance 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.

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.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 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, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

JAFNPP 3.0-5 Amendment Remote Shutdown System 3.3.3.2

SURVEILLANCE REQUIREMENTS


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

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

SURVEILLANCE FREQUENCY

SR 3.3.3.2.1 Perform CHANNEL CHECK for each required In accordance instrumentation channel that is normally with the energized. Sur veillance Frequency Control Program

SR 3.3.3.2.2 Verify each required control circuit and transfer In accordance switch is capable of performing the intended with the function. Sur veillance Frequency Control Program

SR 3.3.3.2.3 Perform CHANEL CALIBRATION for each required In accordance instrumentation channel. with the Sur veillance Frequency Control Program

JAFNPP 3.3.3.2-2 Amendment Primary Containment Isolation Instrumentation 3.3.6.1

SURVEILLANCE REQUIREMENTS


NOTES----------------------------------------

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2.d, 2.g, 7.a, and 7.b; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 2.d, 2.g, 7.a, and 7.b provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY

SR 3.3.6.1.1 Perform CHANNEL CHECK. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.3 ----------------- ------NOTE------- ---------------

For Functions 1.f and 2.f, radiation detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Sur veillance Frequency Control Program

(continued)

JAFNPP 3.3.6.1-4 Amendment Primary Containment Isolation Instrumentation 3.3.6.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.3.6.1.4 Calibrate the trip units. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.5 Perform CHANNEL CALIBRATION. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.6 Calibrate the radiation detectors. In accordance with the Sur veillance Frequency Control Program

SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Sur veillance Frequency Control Program

JAFNPP 3.3.6.1-5 Amendment ECCS - Operating 3.5.1

3.5 EMERGENCY CORE COOLING SYSTEMS (E CCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.


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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS


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

LCO 3.0.4.b is not applicable to High Pressure Coolant Injection (HPCI).

CONDITION REQUIRED ACTION COMPLETION TIME

A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray OR subsystem inop erable. subsystem(s) to OR OPERABLE status. In accordance with the Risk Informed One low pressure coolant Completion Time injection (LPCI) pump in Program both LPCI subsystems inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion AND Time of Condition A not met. B.2 Be in Mode 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

(continued)

JAFNPP 3.5.1-1 Amendment ECCS - Operating 3.5.1

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, In accordance the piping is filled with water from the pump with the discharge valve to the injection valve. Sur veillance Frequency Control Program

SR 3.5.1.2 Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve in with the the flow path, that is not locked, sealed, or Sur veillance otherwise secured in position, is in the correct Frequency Control position. Program

SR 3.5.1.3 Verify ADS pneumatic supply header pressure is In accordance 95 psig. with the Sur veillance Frequency Control Program

SR 3.5.1.4 Verify the RHR System cross tie valves are closed In accordance and power is removed from the electrical valve with the operator. Sur veillance Frequency Control Program

SR 3.5.1.5 Cycle open and closed each LPCI motor operated In accordance valve independent power supply battery charger with the AC input breaker and verify each LPCI inverter Sur veillance output voltage is 576 V and 624 V while Frequency Control supplying the respective bus. Program

(continued)

JAFNPP 3.5.1-4 Amendment RCIC System 3.5.3

3.5 EMERGENCY CORE COOLING SYSTEMS (E CCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.3 RCIC System

LCO 3.5.3 The RCIC System shall be OPERABLE

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS


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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME

A. RCIC System A.1 Verify by administrative Immediately inoperable. means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status. OR

In accordance with the Risk Informed Completion Time Program

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met. AND

B.2 Reduce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure to 150 psig.

JAFNPP 3.5.3-1 Amendment RCIC System 3.5.3

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.5.3.1 Verify the RCIC System piping is filled with water In accordance from the pump discharge valve to the injection with the valve. Sur veillance Frequency Control Program

SR 3.5.3.2 Verify each RCIC System manual, power operated, In accordance and automatic valve in the flow path, that is not with the locked, sealed, or otherwise secured in position, is Sur veillance in the correct position. Frequency Control Program

SR 3.5.3.3 ----------------- ------NOTE------- ---------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1040 psig and In accordance 970 psig, the RCIC pump can develop a flow rate with the 400 gpm against a system head corresponding Sur veillance to reactor pressure. Frequency Control Program

SR 3.5.3.4 ----------------- ------NOTE------- ---------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 165 psig, the RCIC In accordance pump can develop a flow rate 400 gpm against with the a system head corresponding to reactor pressure. Sur veillance Frequency Control Program

(continued)

JAFNPP 3.5.3-2 Amendment RCIC System 3.5.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.5.3.5 ----------------- ------NOTE------- ---------------

1. Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
2. Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or In accordance simulated automatic initiation signal, except for with the valves that are locked, sealed, or otherwise Surveillance secured in the actuated position. Frequency Control Program

JAFNPP 3.5.3-3 Amendment PCIVs 3.6.1.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.6.1.3.3 ----------------- ------NOTES------ ---------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation Prior to entering valve and blind flange that is located inside MODE 2 or 3 from primary containment and not locked, sealed or MODE 4 if otherwise secured and is required to be closed primar y during accident conditions is closed. containment was de-iner ted while in MODE 4, if not per formed within the previous 92 days

SR 3.6.1.3.4 Verify continuity of the traversing incore probe In accordance (TIP) shear isolation valve explosive charge. with the Sur veillance Frequency Control Program

SR 3.6.1.3.5 Verify the isolation time of each power operated, In accordance automatic PCIV, except for MSIVs, is within limits. with the INSERVICE TESTING PROGRAM

SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 In accordance seconds and 5 seconds. with the INSERVICE TESTING PROGRAM

(continued)

JAFNPP 3.6.1.3-8 Amendment Secondary Containment 3.6.4.1

3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment

LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A not AND met. B.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

C. Secondary containment C.1 ---------NOTE---------

inoperable during LCO 3.0.3 is not movement of recently applicable.

irradiated fuel -----------------------

assemblies in the secondary containment. Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

JAFNPP 3.6.4.1-1 Amendment Control Room AC System 3.7.4

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.7.4.1 Verify each control room AC subsystem has the In accordance capability to remove the assumed heat load. with the Sur veillance Frequency Control Program

JAFNPP 3.7.4-3 Amendment AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.2 ----------------- ------NOTE------- ---------------

All EDG subsystem starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each EDG subsystem starts from standby In accordance conditions, force parallels, and achieves: with the

a. In 10 seconds, voltage 3900 V and Sur veillance frequency 58.8 Hz; and Frequency Control Program
b. Steady state voltage 3900 V and 4400 V and frequency 58.8 Hz and 61.2 Hz.

SR 3.8.1.3 ----------------- ------NOTE------- ---------------

1. EDG loading may include gradual loading as recommended by the manufacturer.
2. Momentary transients outside the load range do not invalidate this test.
3. This Surveillance shall be conducted on only one EDG subsystem at a time.
4. This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.

Verify each EDG subsystem is paralleled with In accordance normal, reserve, or backfeed power and each EDG with the is loaded and operates for 60 minutes at a load Sur veillance 2340 kW and 2600 kW. Frequency Control Program

(continued)

JAFNPP 3.8.1-5 Amendment AC Sources - Operating 3.8.1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.1.4 Verify each day tank contains 327 gal of fuel oil. In accordance with the Sur veillance Frequency Control Program

SR 3.8.1.5 Check for and remove accumulated water from each In accordance with day tank the Sur veillance Frequency Control Program

SR 3.8.1.6 Verify that each EDG fuel oil transfer system In accordance with operates to automatically transfer fuel oil from its the Sur veillance storage tank to the associated day tank. Frequency Control Program

SR 3.8.1.7 ----------------- ------NOTE------- ----------------- Only required to be met for each offsite circuit that is not energizing its respective 4.16 kV emergency bus.


----------------------------------- In accordance with Verify automatic and manual transfer of plant power the Sur veillance supply from the normal station service transformer Frequency Control to each offsite circuit. Program

SR 3.8.1.8 ----------------- ------NOTE------- ----------------- If performance with EDG subsystem paralleled with normal, reserve, or backfeed power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.

Verify each EDG subsystem rejects a load greater In accordance with than or equal to its associated single largest post-the Sur veillance accident load, and following load rejection, the Frequency Control frequency is 66.75 Hz. Program (continued)

JAFNPP 3.8.1-6 Amendment Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. One or more EDGs with D.1 Restore stored fuel oil 30 days new fuel oil properties properties to within limit.

not within limits.

E. One or more EDGs with E.1 Restore required starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> required starting air air receiver pressure to receiver pressure < within limits.

150 psig and 110 psig.

F. Requires Action and F.1 Declare associated EDG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR

One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other then condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.8.3.1 Verify each fuel oil storage tank contains a 7 day In accordance supply of fuel. with the Surveillance Frequency Control Program

(continued)

JAFNPP 3.8.3-2 Amendment Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.3.2 Verify lube oil inventory of each EDG is a 7 day In accordance supply. with the Sur veillance Frequency Control Program

SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained with the Diesel within the limits of, the diesel Fuel Oil Testing Fuel Oil Testing Program. Program

SR 3.8.3.4 Verify Each EDG required air start receiver pressure In accordance is 150 psig. with the Sur veillance Frequency Control Program

SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Sur veillance Frequency Control Program

JAFNPP 3.8.3-3 Amendment DC Sources - Operating 3.8.4

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.4.1 Verify battery terminal voltage on float charge is: In accordance

a. 127.8 VDC for 125 VDC batteries, and with the Sur veillance
b. 396.2 VDC for 419 VDC LPCI MOV Frequency Control independent power supply batteries. Program

SR 3.8.4.2 Verify each 125 VDC battery charger supplies In accordance 270 amps at 128 VDC for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. with the Sur veillance OR Frequency Control Verify each 125 VDC battery charger can recharge Program

the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

SR 3.8.4.3 ----------------- ------NOTE------- ---------------

This Surveillance shall not normally be performed in MODE 1, 2, or 3 for the 125 VDC batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance maintain in OPERABLE status, the required with the emergency loads for the design duty cycle when Sur veillance subjected to a battery service test or a modified Frequency Control performance discharge test. Program

(continued)

JAFNPP 3.8.4-3 Amendment DC Sources - Shutdown 3.8.5

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2.3 Initiate action to Immediately restore required DC electrical power subsystem to OPERABLE status.

SURVEILLANCE REQUREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.5.1 ----------------- ------NOTE------- ---------------

The following SRs are not required to be performed: SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.

For DC electrical power subsystem required to In accordance be OPERABLE the fallowing SRs are applicable: with applicable SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SRs SR 3.8.4.4.

JAFNPP 3.8.5-2 Amendment Battery Cell Parameters 3.8.6

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.3 Restore battery cell 31 days parameters to Category A and B limits of Table 3.8.6-1.

B. Required Action and B.1 Declare associated Immediately associated battery inoperable.

Completion Time of Condition A not met.

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

OR One or more batteries with one or more battery cell parameters not within Category C limits.

SURVEILLANCE REQUREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits. In accordance with the Sur veillance Frequency Control Program

(continued)

JAFNPP 3.8.6-2 Amendment Battery Cell Parameters 3.8.6

SURVEILLANCE REQUREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 In accordance Category B limits. with the Surveillance Frequency Control Program

SR 3.8.6.2 Verify average electrolyte temperature of In accordance representative cells is 65°F for each 125 VDC with the battery, and 50°F for each 419 VDC LPCI MOV Surveillance independent power supply battery. Frequency Control Program

JAFNPP 3.8.6-3 Amendment ATTACHMENT 4

License Amendment Request

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333

PROPOSED TECHNICAL SPECIFICATION BASES MARKED-UP PAGES (for information only)

B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-5 B 3.0-8 B 3.0-9 B 3.0-20 B 3.0-21 B 3.0-22

LCO Applicability B 3.0

B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

BASES

LC O s LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the plant is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, 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 an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met.

This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the plant in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the plant (continued)

JAFNPP B 3.0-1 Revision LCO Applicability B 3.0

BASES

LCO 3.0.3 corresponds to the actual condition of the plant. Sometimes, (continued) possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the plant in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. Planned entry into LCO 3.0.3 should be avoided. If it is not practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less effect on plant safety than other practicable alternatives.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the plant, assuming that only the minimum required equipment is OPERABLE.

This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified ti mes to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A plant shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met, a.b. The LCO is no longer applicable, b.c. A Condition exists for which the Required Actions have now been performed.

c.d. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

(continued)

JAFNPP B 3.0-3 Revision LCO Applicability B 3.0

BASES

LCO 3.0.3 The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in (continued) MODE 4 when a shutdown is required during MODE 1 operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching entering the next lower MODE applies. If a lower MODE is reached entered in less time than allowed, however, the total allowable time to reach enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is reached entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reaching entering MODE 3 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for reaching entering MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the plant is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a plant shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the plant. An example of this is in LCO 3.7.7, "Spent Fuel Storage Pool Water Level." LCO 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the plant in a shutdown condition. The Required Action of LCO 3.7.7 to "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the plant in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when

(continued)

JAFNPP B 3.0-4 Revision LCO Applicability B 3.0

BASES

LCO 3.0.4 plant conditions are such that the requirements of the LCO would not (continued) be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

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 infollowing entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with Required ActionsACTIONS that permit continued operation of the plant 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 plant 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 and the Required Actions followed after entry into the Applicability.

For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

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 (continued)

JAFNPP B 3.0-5 Revision LCO Applicability B 3.0

BASES

the affected LCO.

(continued)

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

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

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.

JAFNPP B 3.0-8 Revision (continued)

LCO Applicability B 3.0

BASES

LCO 3.0.5 An example of demonstrating the OPERABILITY of other equipment is (continued) taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system's LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support systems' LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO's Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action

JAFNPP B 3.0-9 Revision SR Applicability B 3.0

BASES SR 3.0.2 When a section 5.5, Programs and Manuals, specification states (continued) that the provisions of SR 3.0.2 are applicable, a 25% extension of the testing interval, whether stated in the specification or incorporated by reference, is permitted.

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Examples of where SR 3.0.2 does not apply are the Primary Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with the applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of regulations.

The TS cannot in and of themselves extend a test interval specified in the regulations directly or by reference.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

(continued)

JAFNPP B 3.0-20 Revision SR Applicability B 3.0

BASES (continued)

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed performed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. When a Section 5.5, Programs and Manuals, specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibil ity to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 specification). This delay period provides adequate time to complete perform Surveillances that have been missed. This delay period permits the completion performance of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion performance of the Surveillance.

The basis for this delay period includes consideration of plant 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 plant conditions, operating conditions, 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.

SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.

Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a (continued)

JAFNPP B 3.0-21 Revision SR Applicability B 3.0

BASES SR 3.0.3 portion thereof, has ever been performed, and any other indications, (continued) tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

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 conveniencerepeatedly 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 addit ion to plant 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, Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary (continued)

JAFNPP B 3.0-22 Revision