ML24268A198
| ML24268A198 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 12/09/2024 |
| From: | Robert Elliott, Rojas C Office of Nuclear Reactor Regulation |
| To: | Technical Specifications Task Force |
| References | |
| EPID L-2024-PMP-0003 | |
| Download: ML24268A198 (8) | |
Text
DRAFT SAFETY EVALUATION 1
2 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 3
4 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 5
6 TSTF-597, REVISION 0, ELIMINATE LCO 3.0.3 MODE 2 REQUIREMENT 7
8 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 9
10 (EPID: L-2024-PMP-0003) 11 12
1.0 INTRODUCTION
13 14 By letter dated March 15, 2024 (Agencywide Documents Access and Management System 15 (ADAMS) Accession No. ML24075A080) as modified by supplement dated September 16, 2024 16 (ML24260A221), the Technical Specifications Task Force (TSTF) submitted traveler TSTF-597, 17 Revision 0, Eliminate LCO 3.0.3 Mode 2 Requirement. Traveler TSTF-597, Revision 0, 18 proposed changes to the Standard Technical Specifications (STS) for boiling-water reactor 19 (BWR) designs. These changes would be incorporated into future revisions of NUREG-1433 20 and NUREG-1434.
21 22 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 23 Electric Plants, BWR/4, NUREG-1433, Volume 1, Specifications, and Volume 2, 24 Bases, Revision 5, September 2021 (ML21272A357 and ML21272A358, respectively).1 25 26 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 27 Electric Plants, BWR/6, NUREG-1434, Volume 1, Specifications, and Volume 2, 28 Bases, Revision 5, September 2021 (ML21271A582 and ML21271A596, respectively).2 29 30 The proposed change would revise the shutdown requirements in STS Limiting Condition for 31 Operation (LCO) 3.0.3 by removing the requirement to place the unit in MODE 2 prior to 32 entering MODE 3. This STS change will be made available to licensees through the 33 Consolidated Line Item Improvement Process (CLIIP).
34 35 1.1 Description of the Current Limiting Condition for Operation 3.0.3 Requirement 36 37 In NUREG-1433 and NUREG-1434, LCO 3.0.3 requires the unit to be placed into a MODE or 38 other specified condition outside the currently applicable modes when an LCO is not met, and 39 any of the following conditions are true: 1) the associated actions are not met, 2) an associated 40 action is not provided, or 3) LCO 3.0.3 entry is directed by the associated actions. LCO 3.0.3 41 requires that action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit in MODE 2 (Startup) within 42 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />s3, MODE 3 (Hot Shutdown) within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and MODE 4 (Cold Shutdown) within 43 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
44 45 1 NUREG-1433 provides the STS for BWR/4 plant designs but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.
2 NUREG-1434 provides the STS for BWR/6 plant designs but is also representative in some cases of the BWR/5 plant design.
3 A reviewers note in NUREG-1433 states that plants may extend this time from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to a plant-specific time, if the licensee supports the extended time with plant-specific data.
The intent of each time limit to enter subsequently lower modes of operation is to ensure an 1
orderly and timely shutdown when operation cannot be maintained within the limits for safe 2
operation as defined by the LCO and its ACTIONS. Several LCOs identify these conditions and 3
direct entry into LCO 3.0.3, such as when there is a loss of function of either low or high 4
pressure ECCS (STS LCO 3.5.1) and inoperable offsite and onsite AC sources (STS 5
6 7
1.2 Description of Boiling Water Reactor Modes of Operation 8
9 Table 1.1-1 shown below from NUREG-1433 and NUREG-1434 describes the conditions 10 required for each mode of operation. The position of the reactor mode switch position and 11 reactor coolant temperature are the main parameters that determine reactor MODE.
12 Additionally, reactor power also drives the reactor MODE during startup and shutdown 13 operations.
14 15 During a typical BWR unit startup, the plant starts in MODE 4 (Cold Shutdown) with all control 16 rods inserted and average reactor coolant temperature below 200 F. The mode switch is then 17 moved to the Startup/Hot Standby position and MODE 2 (Startup) is entered. Control rods are 18 withdrawn to bring the reactor critical, and the reactor coolant heats up. Control rods are further 19 withdrawn, and reactor power is increased to approximately 10% when the mode switch is taken 20 to Run and the reactor enters MODE 1 (Power Operation) as the unit is eventually taken to full 21 power.
22 23 During a typical BWR unit shutdown, reactor power is reduced by inserting control rods and 24 reducing core flow with the recirculation system. Upon reducing power to approximately 10%,
25 there are two methods to continue the shutdown.
26 27 The first and most frequently performed method involves inserting a low-power reactor SCRAM 28 by placing the reactor mode switch to Shutdown. This action transitions the unit from MODE 1 29 directly to MODE 3 (Hot Shutdown) and skips entering MODE 2. The shutdown then continues 30 by cooling the reactor down further until the average reactor coolant temperature is reduced to 31 less than or equal to 200 F, at which time the unit enters MODE 4. This is typically the quicker 32 method of shutting down a BWR.
33 34 The second method of shutting down a BWR is referred to as a soft shutdown. Upon reaching 35 10% reactor power, the reactor mode switch is moved to Startup/Hot Standby and MODE 2 is 36 entered. Control rods continue to be inserted individually until all rods have been inserted. At 37 that point, the reactor mode switch is moved to the Shutdown position and MODE 3 is entered.
38 The reactor is cooled down as in the first method and MODE 4 is entered when the average 39 reactor coolant temperature is reduced to less than or equal to 200 F. This method is utilized to 40 avoid a hydraulic transient on the control rod drive (CRD) system from the SCRAM and improve 41 CRD reliability.
42 43 1
2 1.3 Proposed Changes to the Standard Technical Specifications 3
4 Traveler TSTF-597, Revision 0, proposed revisions to LCO 3.0.3 for NUREG-1433 and 5
NUREG-1434 to remove the requirement to be in MODE 2 prior to entering MODE 3.
6 7
1.3.1 Proposed Changes to Volume 1 of NUREG-1433 and NUREG-1434 8
9 The proposed change would modify STS LCO 3.0.3 in NUREG-1433 and NUREG-1434 as 10 follows:
11 12 LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not 13 met, an associated ACTION is not provided, or if directed by the 14 associated ACTIONS, the unit shall be placed in a MODE or other 15 specified condition in which the LCO is not applicable. Action 16 shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
17 18
- a.
MODE 2 within [7] hours, 19 20 ab. MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and 21 22 bc. MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
23 24 Exceptions to this Specification are stated in the individual 25 Specifications.
26 27 Where corrective measures are completed that permit operation in 28 accordance with the LCO or ACTIONS, completion of the actions 29 required by LCO 3.0.3 is not required.
30 31 LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
32 33
REVIEWER'S NOTE-------------------------
34 The brackets around the time provided to reach MODE 2 allow a 35 plant to extend the time from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to a plant specific time. Before 36 the time can be changed, plant specific data must be provided to 1
support the extended time.
2 3
4 The effect of the change would be to better support the use of the low-power SCRAM method of 5
shutting down the plant when shutting down in accordance with LCO 3.0.3. The proposed 6
change would remove from NUREG-1433, the Reviewers Note at the end of LCO 3.0.3 that 7
discusses the reason for the brackets around the MODE 2 time requirement and the process by 8
which licensees can extend the time. This change would only apply to NUREG-1433; this note 9
is not in NUREG-1434 due to the capability of BWR/6 plants to shut down more quickly.
10 11 1.3.2 Proposed Changes to the STS Bases 12 13 The proposed change would modify the example in the STS Bases for LCO 3.0.3 (i.e., in 14 Volume 2 of NUREG-1433 and NUREG-1434) as shown below:
15 16 For example, if MODE 2 is 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 entering 17 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 entering MODE 3 is not 18 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 />.
19 20 would be replaced with 21 22 For example, if MODE 3 is entered in 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, then the time allowed for entering 23 MODE 4 is the next 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, because the total time for entering MODE 4 is not 24 reduced from the allowable limit of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
25 26 The proposed STS Bases change would clarify the application of LCO 3.0.3 by using an 27 example that is consistent with the revised LCO 3.0.3 requirements.
28 29
2.0 REGULATORY EVALUATION
30 31 As described in the Commissions Final Policy Statement on Technical Specifications 32 Improvements for Nuclear Power Reactors (58 FR 39132, dated July 22, 1993), the NRC and 33 industry task groups for new STS recommended that new STS include greater emphasis on 34 human factors principles in order to add clarity and understanding to the text of the STS, and 35 provide improvements to the Bases of the STS, which provide [] the purpose for each 36 requirement in the STS. The improved vendor-specific STS were developed and issued by the 37 NRC in September 1992.
38 39 The Commissions Final Policy Statement states that each LCO, Action, and Surveillance 40 Requirement (SR) should have supporting Bases, and [t]he Bases should, at a minimum, 41 address [certain] questions and cite references to appropriate licensing documentation (e.g.,
42 FSAR or Topical Report) to support the Bases.
43 44 The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires 45 that:
46 47 Each license authorizing operation of a utilization facility will include 48 technical specifications. The technical specifications will be derived from the 49 analyses and evaluation included in the safety analysis report, and amendments 50 thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; 51 technical information]. The Commission may include such additional technical 1
specifications as the Commission finds appropriate.
2 3
10 CFR 50.36(c) states the categories of items that must be included in TS. Among other items, 4
the regulation requires that TS include LCOs. 10 CFR 50.36(c)(2)(i) states that:
5 6
Limiting conditions for operation are the lowest functional capability or 7
performance levels of equipment required for safe operation of the facility. When 8
a limiting condition for operation of a nuclear reactor is not met, the licensee shall 9
shut down the reactor or follow any remedial action permitted by the technical 10 specifications until the condition can be met.
11 12 The NRC staffs guidance for the review of TSs is in NUREG-0800, Standard Review Plan for 13 the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor]
14 Edition (SRP), Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 15 (ML100351425).
16 17
3.0 TECHNICAL EVALUATION
18 19 In traveler TSTF-597, Revision 0, the TSTF proposed to modify STS 3.0.3 for NUREG-1433 and 20 NUREG-1434 to remove the MODE 2 requirement. The requirements to be in MODE 3 within 21 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> would remain unchanged. The NRC staff reviewed the 22 proposed change to determine if: 1) the shutdown requirements in the proposed LCO 3.0.3 are 23 consistent with those contained in other LCOs in the STS, 2) there is a significant safety benefit 24 to requiring entry into MODE 2 while shutting down the plant, and 3) the proposal meets all 25 applicable regulatory requirements.
26 27 The STS Bases for LCO 3.0.3 state, 28 29 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 30 before initiating a change in unit operation. This includes time to permit the 31 operator to coordinate the reduction in electrical generation with the load 32 dispatcher to ensure the stability and availability of the electrical grid. The time 33 limits specified to reach lower MODES of operation permit the shutdown to 34 proceed in a controlled and orderly manner that is well within the specified 35 maximum cooldown rate and within the capabilities of the unit, assuming that 36 only the minimum required equipment is OPERABLE.
37 38 When accounting for the initial hour, LCO 3.0.3 requires the plant to be in MODE 2 within the 39 next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (for a total of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> from the time the LCO is entered), MODE 3 within the next 40 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (for a total of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> from the time the LCO is entered) and MODE 4 within the 41 next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (for a total of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> from the time the LCO is entered). This means that the 42 total time to place the unit in MODE 4 once the shutdown begins is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
43 44 Each LCO in STS Sections 3.1 through 3.10 specifies the operating modes or other conditions 45 in which the LCO must be met (referred to as the mode of applicability). Typically, the Actions in 46 other LCOs (other than LCO 3.0.3) require a plant to exit the mode of applicability by placing the 47 plant in an operating MODE where the LCO does not apply when a significant degradation of 48 safety-related plant SSC(s) occurs or if the LCO Required Actions are not completed within the 49 specified Completion Time (CT). Accordingly, the NRC staff reviewed other STS LCOs to 50 determine if the LCO 3.0.3 MODE 2 requirement was consistent with other plant conditions that 51 require exiting the mode of applicability. Specifically, the NRC staff reviewed whether other 1
LCOs required going to MODE 2 when exiting the mode of applicability requires entry into 2
MODE 3 or MODE 4. The staff found that the MODE 2 requirement in LCO 3.0.3 is not 3
consistent with the requirements for all other LCOs where the Actions require placing the plant 4
in MODE 3 or MODE 4. The staff found that even for plant conditions that represent significant 5
degradation in plant safety, the STS do not require going to MODE 2 before going to MODE 3.
6 In addition, in all cases where the STS Required Actions direct entry into MODE 3 or MODE 4, 7
the CTs allowed for placing the unit in MODE 3 and MODE 4 are the same as allowed in 8
LCO 3.0.3 (after accounting for the above-discussed one-hour preparation period built into 9
10 11 For example, LCO 3.6.1.1, Primary Containment, Required Action B, requires primary 12 containment to be operable in MODES 1, 2, and 3. If primary containment is inoperable and not 13 restored to operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, then Required Action B requires the plant be placed in a 14 MODE in which the LCO does not apply (i.e., place the plant in MODE 4). There is no 15 requirement to enter MODE 2 while shutting down the plant. Another example is LCO 3.4.3, 16 Safety/Relief Valves (S/RVs), Required Action C in NUREG-1433. When the minimum number 17 of required S/RVs are inoperable, Required Action C requires the plant to be placed in a MODE 18 in which the LCO does not apply (i.e., MODE 4). In both examples, the plant is significantly 19 degraded, and the STS requires entering MODE 3 (Hot Shutdown) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 20 (Cold Shutdown) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> which is the same time allotted in LCO 3.0.3 once accounting 21 for the one-hour preparation time incorporated into LCO 3.0.3. Neither of these plant conditions 22 have a requirement to enter MODE 2 within any amount of time. The staff found that entry into 23 MODE 2 is not required in any LCOs that require entry into MODE 3 or MODE 4 when exiting 24 the mode of applicability is required.
25 26 The NRC staffs review of the STS also found a small number of LCOs that only apply in 27 MODE 1. An example of these is LCO 3.3.4.2, Anticipated Transient Without Scram 28 Recirculation Pump Trip (ATWS-RPT) Instrumentation, in NUREG-1433. When the LCO is only 29 applicable in MODE 1, then the STS require entry in MODE 2 when exiting the mode of 30 applicability. The staff considered whether the removal of the MODE 2 requirement in LCO 3.0.3 31 could potentially have a nonconservative effect on these LCOs. The staffs review found that 32 each of these LCOs have their own condition which directs entry into MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if 33 the Required Actions and associated CTs are not met. Accordingly, the staff concludes that 34 entry into LCO 3.0.3 when these LCOs are not met is not likely. However, if the plant did have to 35 enter LCO 3.0.3 due to one of these LCOs not being met, the proposed LCO 3.0.3 would 36 conservatively require the plant to be placed in MODE 3. MODE 3 would be conservative 37 relative to MODE 2 since entry into MODE 3 would require all control rods to be driven in, 38 shutting down the reactor. Accordingly, the staff concludes that the proposed change to 39 LCO 3.0.3 would have negligible safety impact on LCOs that are only applicable in MODE 1.
40 41 The NRC staff also evaluated LCO 3.0.3s basis for requiring the plants be in MODE 2 within 42 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and determined it is based on one hour to prepare for shutting the plant down plus 43 engineering judgement that six hours is a reasonable amount of time to reduce power and enter 44 MODE 2 in a controlled and orderly manner. There is no specific regulatory or safety basis in 45 any safety analysis requiring entry into MODE 2 within a certain amount of time, so removal of 46 the requirement would not invalidate any safety analysis. Further, the NRC staff did not identify 47 any safety basis for including a requirement to enter MODE 2 before entering MODE 3 in 48 LCO 3.0.3. In addition, except for LCOs that are only applicable in MODE 1 discussed above, 49 the removal of the MODE 2 requirement in LCO 3.0.3 will not impact any LCO that requires 50 entry into MODE 3 and/or 4. This is because the licensee would still need to complete the 51 shutdown by taking the plant to MODE 4 (i.e., be in MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and MODE 4 1
within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />). Based on this and the staffs analysis of other LCOs in the STS, the staff 2
concludes there is no safety reason to require entry into MODE 2 prior to entry into MODE 3 3
and MODE 4 in LCO 3.0.3.
4 5
10 CFR 50.36(c)(2)(i) states:
6 7
Limiting conditions for operation are the lowest functional capability or 8
performance levels of equipment required for safe operation of the facility. When 9
a limiting condition for operation of a nuclear reactor is not met, the licensee shall 10 shut down the reactor or follow any remedial action permitted by the technical 11 specifications until the condition can be met.
12 13 LCO 3.0.3 is the default condition for this requirement in that it directs shutting down the plant 14 when an LCO is not met and either the LCO does not include remedial actions, or the licensee 15 fails to complete the remedial actions within the specified CT. The regulation does not specify 16 the time required to shut down. As noted above, the NRC staff has used engineering judgement 17 to establish the LCO-required shut down times based on plant operational experience. Based 18 on the staffs comparison of LCO 3.0.3 requirements with those contained in other STS LCOs, 19 the staff concludes that the proposed revision to LCO 3.0.3 would continue to meet 10 CFR 20 50.36(c)(2)(i) since the LCO 3.0.3 requirements would align with all other LCOs on the times to 21 reach MODE 3 and MODE 4 (after accounting for the above-discussed one-hour preparation 22 period built into LCO 3.0.0) and in not requiring entry into MODE 2 while shutting down.
23 24 Finally, the LCO 3.0.3 MODE 2 requirement doesnt align with typical BWR shutdown 25 operations. As stated in Section 1.2, the typical BWR shutdown process transitions from 26 MODE 1 to MODE 3 via a low-power reactor SCRAM. As such, the proposed change to remove 27 the MODE 2 requirement from LCO 3.0.3 would serve to better align with typical BWR shutdown 28 operations, as well as remove an unnecessary distraction placing time pressure on the 29 operators.
30 31 Based on the evaluation above, the NRC staff concludes that the requirement to enter MODE 2 32 in LCO 3.0.3 can be removed since it alleviates unwarranted time pressure on licensees while 33 still maintaining a reasonable assurance of safety. Therefore, the staff finds that removing the 34 requirement for entry into MODE 2 in LCO 3.0.3 from NUREG-1433 and NUREG-1434 is 35 acceptable.
36 37 3.1 Evaluation of Proposed STS Bases Changes 38 39 This traveler will become part of the next major revision of the NRCs STS Bases NUREG 40 documents. As such, the NRC staff assessed the proposed Bases changes included in TSTF-597 41 to determine if they addressed the items in the Commissions Final Policy Statement described in 42 Section 2.0 above. For the reasons below, the NRC staff found that the proposed STS Bases 43 changes sufficiently met the Final Policy Statement.
44 45 The Final Policy Statement says that Bases should provide the justification for the TS, i.e., discuss 46 which Policy Statement criterion requires it to be in the TS. This standard continues to be met 47 because the proposed STS Bases changes are consistent with the proposed LCO 3.0.3 change.
48 Additionally, they did not affect the discussion of which Policy Statement criterion required this to 49 be in the STS.
50 51
4.0 CONCLUSION
1 2
The NRC staff reviewed traveler TSTF-597, Revision 0, which proposed changes to STS found in 3
NUREG-1433 and NUREG-1434. The NRC staff determined that the proposed changes to the 4
STS continue to meet the Commissions Final Policy Statement on Technical Specifications 5
Improvements for Nuclear Power Reactors and 10 CFR 50.36. Additionally, the NRC staff 6
reviewed the changes to the STS and found them to be technically clear and consistent with 7
customary terminology and format in accordance with SRP Chapter 16.0. The NRC staff 8
reviewed the proposed changes to the actions required by LCO 3.0.3 and concludes that the 9
changes continue to provide reasonable assurance of adequate protection of the health and 10 safety of the public. Therefore, the NRC staff concludes that the proposed STS changes are 11 acceptable.
12 13 Principal Contributors: C. Rojas, NRR/DSS 14 R. Elliott, NRR/DSS 15 16 Date: December 9, 2024 17