Text

Transmittal of TSTF-585, Revision 4, Revise LCO 3.0.3 to Require Managing Risk
	ML25066A098
Person / Time
Site:	Technical Specifications Task Force, 99902042
Issue date:	03/07/2025
From:	Jurek S, Richards A, Steinman R, Vaughan J; Technical Specifications Task Force
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	TSTF 25-05 TSTF-585, Rev 4
	Download: ML25066A098 (1)
	v • d • e

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF March 7, 2025 TSTF-25-05 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-585, Revision 4, "Revise LCO 3.0.3 to Require Managing Risk" Enclosed for NRC review is TSTF-585, Revision 4, "Revise LCO 3.0.3 to Require Managing Risk."

On November 13, 2024, the TSTF and the NRC held a public workshop to discuss TSTF-585 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24324A178). The purpose of the meeting was for the NRC staff and the industry to discuss scenarios of how a licensee would implement the TS changes proposed in draft Revision 3 to TSTF-585 (ML24016A270).

The TSTF has revised TSTF-585 based on the discussions at the workshop. Limiting Condition for Operation (LCO) 3.0.3 is revised to reference to appropriate risk management actions instead of required risk management actions, and a reference to the risk assessment was not performed is changed to the risk assessment was not completed. There are no other changes to the proposed Technical Specifications (TS).

In addition, the traveler justification and Bases are revised to:

More fully explain how risk is determined starting with the baseline, zero-maintenance risk;

Establish the limits for acceptable plant risk for continuing plant operation;

Add a threshold for instantaneous risk to avoid high-risk failures that should result in shutdown;

Provide a more complete discussion of Risk Management Actions (RMAs);

Discuss cross-unit dependencies;

Discuss the circumstances when risk can be evaluated qualitatively if quantitative evaluation is not possible;

Expand the discussion of conservative operation actions to shut down the plant if appropriate;

Expand the discussion of the LCO 3.0.3 planned entries;

TSTF 25-05 March 7, 2025 Page 2

Discuss that assessing plant risk is an ongoing activity while in LCO 3.0.3;

State that the determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination; and

Provide additional justification to support the staff's Safety Evaluation.

The changes to the justification are indicated by revision bars in the right margin.

The TSTF and the NRC have been discussing the revision to LCO 3.0.3 for four years. The TSTF and NRC have exchanged several rounds of drafts and comments, and we have held two public workshops. We believe that Revision 4 of the traveler provides the NRC with sufficient information to review the change. We request that the NRC provide a schedule that will permit completing your review of TSTF-585, Revision 4, by the end of the calendar year.

The Technical Specifications Task Force should be billed for the review of the traveler.

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

Jordan L. Vaughan (PWROG/B&W)

Shane M. Jurek, PE (BWROG)

Andrew M. Richards, Jr. (PWROG/W)

Rebecca L. Steinman, PhD, PE (PWROG/CE) cc:

Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch

TSTF-585, Rev. 4 PWROG-9, Rev. 0 NUREGs Affected:

Revise LCO 3.0.3 to Require Managing Risk Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Avoids a Plant Shutdown Changes Marked on ISTS Rev 5.0 PWROG RISD & PA (if applicable): PA-LSC-1708 RS-2019-005 See attached.

Revision History OG Revision 0 Revision Status: Closed Original Issue Revision

Description:

Revision Proposed by:

PWROG Owners Group Review Information Date Originated by OG:

25-Feb-21 Owners Group Comments (No Comments)

Date: 19-Mar-21 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

19-Mar-21 Date Distributed for Review 19-Mar-21 TSTF Comments:

(No Comments)

Date: 05-Apr-21 TSTF Resolution:

Approved TSTF Revision 1 Revision Status: Closed The draft traveler was renamed and revised based on NRC comments.

Revision

Description:

Revision Proposed by:

TSTF 07-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-585, Rev. 4 PWROG-9, Rev. 0 TSTF Revision 1 Revision Status: Closed Owners Group Review Information Date Originated by OG:

26-Oct-21 Owners Group Comments (No Comments)

Date: 11-Nov-21 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

11-Nov-21 Date Distributed for Review 11-Nov-21 TSTF Comments:

(No Comments)

Date: 30-Nov-21 TSTF Resolution:

Approved TSTF Revision 2 Revision Status: Closed The traveler was revised to address NRC comments:

- Certain specifications were revised to require a plant shutdown instead of entering LCO 3.0.3.

- The changes to LCO 3.0.3 were minimized.

- The justification was expanded to provide more information on applying the Maintenance Rule guidance to emergent conditions.

- The justification was expanded to discuss transition between LCO 3.0.3.a and LCO 3.0.3.b.

Revision

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

02-Feb-23 Owners Group Comments (No Comments)

Date: 17-Feb-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

17-Feb-23 Date Distributed for Review 17-Feb-23 TSTF Comments:

(No Comments)

Date: 06-Mar-23 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

06-Mar-23 07-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-585, Rev. 4 PWROG-9, Rev. 0 TSTF Revision 2 Revision Status: Closed NRC Requests Changes: TSTF Will Revise Final Resolution:

TSTF Revision 3 Revision Status: Closed Based on feedback from the NRC, TSTF-585 was significantly revised. The traveler was renamed from "Provide an Alternative to the LCO 3.0.3 One-Hour Preparation Time" to "Revise LCO 3.0.3 to Require Managing Risk."

LCO 3.0.3 was revised to require a risk assessment and implementation of risk management actions within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of entry into LCO 3.0.3. If the risk assessment determines that the risk of continuing plant operaiton is acceptable, the risk management actions are implemented, and the entry into LCO 3.0.3 was not planned, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is provided before initiating a plant shutdown. Otherwise, an immediate shutdown is must be initiated at the end of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period.

Revision

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

23-Oct-23 Owners Group Comments (No Comments)

Date: 06-Nov-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

27-Nov-23 Date Distributed for Review 27-Nov-23 TSTF Comments:

(No Comments)

Date: 12-Dec-23 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

12-Dec-23 Superceded by Revision Final Resolution:

TSTF Revision 4 Revision Status: Active The TSTF and NRC held a workshop on TSTF-585 on November 13, 2024. TSTF-585 is revised to address the discussions at the meeting:

The justification and TS Bases are expanded to provide more detail on the risk assessment and the risk Revision

Description:

Revision Proposed by:

TSTF 07-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-585, Rev. 4 PWROG-9, Rev. 0 Affected Technical Specifications TSTF Revision 4 Revision Status: Active management actions.

The acceptable risk for continuing operation is revised to 1E-5 ICDP, 1E-6 ILERP, 1E-3 CDF, and 1E-4 LERF.

LCO 3.0.3 is revised to refer to "appropriate" risk management actions instead of "required" risk management actions.

LCO 3.0.3 is revised to refer to risk assessments that are not "completed" instead of not "performed."

Owners Group Review Information Date Originated by OG:

07-Feb-25 Owners Group Comments The justification and Bases were revised to state that the impact on plant risk is evaluated from the baseline, zero-maintenance, condition. This is consistent with NUMARC 93-01.

Minor editorial corrections or improvements.

Date: 21-Feb-25 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

25-Feb-25 Date Distributed for Review 25-Feb-25 TSTF Comments:

(No Comments)

Date: 06-Mar-25 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

07-Mar-25 LCO 3.0.3 LCO Applicability LCO 3.0.3 Bases LCO Applicability Action 3.8.4.E NUREG(s)- 1430 1431 1432 1433 1434 Only New Action Change

Description:

DC Sources - Operating Action 3.8.4.E Bases NUREG(s)- 1430 1431 1432 1433 1434 Only New Action Change

Description:

DC Sources - Operating Action 3.8.5.F Distribution Systems - Operating Action 3.8.5.F Bases Distribution Systems - Operating 07-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-585, Rev. 4 PWROG-9, Rev. 0 Action 3.7.2.B NUREG(s)- 1430 1431 1432 Only Main Steam Isolation Valves (MSIVs)

Action 3.7.2.B Bases NUREG(s)- 1430 1431 1432 Only Main Steam Isolation Valves (MSIVs)

Action 3.8.4.D NUREG(s)- 1430 1431 1432 Only DC Sources - Operating Action 3.8.4.D Bases NUREG(s)- 1430 1431 1432 Only DC Sources - Operating Action 3.8.9.E NUREG(s)- 1430 1431 1432 Only Distribution Systems - Operating Action 3.8.9.E Bases NUREG(s)- 1430 1431 1432 Only Distribution Systems - Operating Action 3.1.6.B NUREG(s)- 1430 Only APSR Alignment Limits Action 3.1.6.B Bases NUREG(s)- 1430 Only APSR Alignment Limits Action 3.6.10.C NUREG(s)- 1431 Only HIS (Ice Condenser)

Action 3.6.10.C Bases NUREG(s)- 1431 Only HIS (Ice Condenser)

Action 3.8.4.F NUREG(s)- 1433 1434 Only DC Sources - Operating Action 3.8.4.F Bases NUREG(s)- 1433 1434 Only DC Sources - Operating Action 3.8.9.F NUREG(s)- 1433 1434 Only Distribution Systems - Operating Action 3.8.9.F Bases NUREG(s)- 1433 1434 Only Distribution Systems - Operating Action 3.8.4.G NUREG(s)- 1434 Only DC Sources - Operating Action 3.8.4.G Bases NUREG(s)- 1434 Only DC Sources - Operating 07-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-585, Rev. 4 Page i Table of Contents

1.

SUMMARY

DESCRIPTION......................................................................................................... 1

2.

DETAILED DESCRIPTION.......................................................................................................... 1 2.1.

Background.................................................................................................................... 1 2.2.

Current Technical Specifications Requirements............................................................ 2 2.3.

Reason for the Proposed Change.................................................................................... 4 2.4.

Description of the Proposed Change.............................................................................. 5

3.

TECHNICAL EVALUATION....................................................................................................... 9 3.1.

LCO 3.0.3 Change Overview......................................................................................... 9 3.1.1.

The Proposed Change is Consistent with the Regulations........................................ 9 3.1.2.

The Proposed Change Improves Plant Safety........................................................... 9 3.1.3.

The Proposed Change Leverages Existing Risk Management Tools..................... 11 3.1.3.1.

10 CFR 50.65(a)(4).......................................................................................... 11 3.1.3.2.

NEI 18-10......................................................................................................... 12 3.1.3.3.

FLEX and Other Mitigating Strategies............................................................ 13 3.1.3.4.

Support for the Commission's Policy Statement on Technical Specifications and Strategic Plan............................................................................................. 13 3.2.

LCO 3.0.3 Detailed Justification.................................................................................. 14 3.2.1.

Time to Assess and Manage Risk and Implement Risk Management Actions...... 14 3.2.2.

Plant Operation May Continue if Risk is Acceptable............................................. 15 3.2.3.

Plant Operation May Continue if Appropriate Risk Management Actions are Implemented........................................................................................................... 16 3.2.4.

Plant Operation May Continue if the LCO 3.0.3 Entry is Unplanned.................... 17 3.2.5.

Basis for the 24-Hour Period.................................................................................. 18 3.3.

LCO 3.0.3 Editorial Changes....................................................................................... 20 3.4.

Other TS Changes........................................................................................................ 20 3.4.1.

Other TS Evaluation............................................................................................... 20 3.4.2.

Other TS Changes................................................................................................... 22 3.4.2.1.

NUREG-1430, TS 3.1.6, "AXIAL POWER SHAPING ROD (APSR)

Alignment Limits"............................................................................................ 22 3.4.2.2.

NUREG-1431, TS 3.6.10, "Hydrogen Ignition System (HIS)"....................... 22 3.4.2.3.

NUREG-1430, NUREG-1431, and NUREG-1432, TS 3.7.2, "Main Steam Isolation Valves (MSIVs)"............................................................................... 22 3.4.2.4.

NUREG-1430 through NUREG-1434 TS 3.8.4, "DC Sources - Operating"... 23

TSTF-585, Rev. 4 Page ii 3.4.2.5.

NUREG-1430 through NUREG-1434 TS 3.8.9, "Distribution Systems -

Operating"........................................................................................................ 23 3.5.

TS Bases Changes........................................................................................................ 23 3.6.

Conclusion.................................................................................................................... 25

4.

REGULATORY EVALUATION................................................................................................ 25

5.

REFERENCES.............................................................................................................................. 26

TSTF-585, Rev. 4 Page 1

1.

SUMMARY

DESCRIPTION The proposed change revises Limiting Condition for Operation (LCO) 3.0.3 to require assessing and managing plant risk whenever LCO 3.0.3 is entered. Six hours are provided to perform the risk assessment and to implement any appropriate risk management actions. If the assessment determines that the risk of continuing plant operation is acceptable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is provided to prepare for a plant shutdown, to perform repairs, or to request relief from the NRC. If the assessment determines that the risk of continuing plant operation is not acceptable, then initiation of actions to shut down the plant is required. The proposed change also revises or adds some Technical Specifications (TS) Required Actions to require a plant shutdown instead of entry into LCO 3.0.3. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-14341.

2. DETAILED DESCRIPTION 2.1. Background LCO 3.0.3 requires a plant shutdown under three conditions:

1.

An LCO is not met, and the associated Actions are not met;

2.

An LCO is not met, and an associated Action is not provided; or

3.

An LCO is not met, and LCO 3.0.3 entry is directed by the associated Actions.

LCO 3.0.3 requires initiation of actions to shut down the plant within one hour if any of these conditions are met.

LCO 3.0.3 entries can be explicit or implicit. Explicit LCO 3.0.3 entries are directed by a Required Action in a specification, which typically states, "Enter LCO 3.0.3," with a Completion Time of "Immediately." Implicit LCO 3.0.3 entries result from a specification not providing an Action that reflects a failure to meet the LCO. The most common use of implicit LCO 3.0.3 entries is to not include an Action for more than one inoperable train or subsystem in a TS that requires multiple trains or subsystems to be operable. For example, a circulating water system 1 NUREG-1430 provides the STS for Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

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

NUREG-1434 provides the STS for the BWR/6 plant design, and is representative, in some cases, of the BWR/5 plant design.

TSTF-585, Rev. 4 Page 2 TS could require two trains to be operable but only provide an Action for one inoperable train. If both trains are inoperable, LCO 3.0.3 is applicable.

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.36(c)(2), "Limiting Conditions for Operation," states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by providing a requirement to shut down the reactor if an LCO is not met and the TS does not provide any other remedial action.

Generic Letter 80-30 mandated all licensees revise the equivalent to LCO 3.0.3 to require pressurized water reactors (PWRs) to be in Hot Standby within one hour and boiling water reactors (BWRs) to be in Hot Shutdown within six hours. However, the 1980 versions of the STS provided one hour to prepare before initiating a shutdown. The purpose of the one-hour allowance was not discussed in the STS Bases, but Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," revised the Bases to state, "One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid." All operating plants have adopted the one-hour time to prepare in their equivalent of LCO 3.0.3.

In 1993, the NRC promulgated 10 CFR 50.65(a)(4) (i.e., the Maintenance Rule), which states, "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities." The industry has implemented this requirement using the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

which is endorsed by NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The guidance is followed to reduce the likelihood of initiating events, reduce the likelihood of the unavailability of redundant trains, and increase the likelihood of successful operator actions in response to an initiating event. The risk assessment and management activities required by 10 CFR 50.65(a)(4) are performed when TS equipment is inoperable, such as the circumstances that can result in entry into LCO 3.0.3.

2.2. Current Technical Specifications Requirements In the Pressurized Water Reactor (PWR) STS (NUREG-1430, NUREG-1431, and NUREG-1432), LCO 3.0.3 states:

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,

TSTF-585, Rev. 4 Page 3

b.

MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c.

MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

In the Boiling Water Reactor (BWR) STS (NUREG-1433 and NUREG-1434), the LCO 3.0.3 requirements reflect the differences between the PWR and BWR Mode definitions, but is otherwise the same:

place the unit, as applicable, in:

a.

MODE 2 within [7]2 hours,

b.

MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c.

MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement," was approved by the NRC on December 26, 2024 (ADAMS Accession No. ML24358A224.) TSTF-597 removed the BWR STS requirement to be in Mode 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . Adoption of TSTF-597 and TSTF-585 in any order does not affect the acceptability of either traveler.

2 The NUREG-1433 TS include a Reviewer's Note that states that a longer time to reach MODE 2 may be justified on a plant-specific basis. The Reviewer's Note was removed by TSTF-597.

TSTF-585, Rev. 4 Page 4 Some TS Actions direct entry into LCO 3.0.3. The following specifications explicitly require entering LCO 3.0.3 in the stated Condition with a Completion Time of "Immediately" and are proposed to be revised:

TS Number NUREG TS Title Condition 3.8.9 1430 1431 1432 1433 1434 Distribution Systems -

Operating Two or more electrical power distribution systems are inoperable that result in a loss of function.

Some specifications may result in implicit entry into LCO 3.0.3 by not providing Actions for all Conditions related to failure to meet the LCO. The following specifications may result in implicit entry into LCO 3.0.3 and are proposed to be revised:

TS Number NUREG TS Title Condition 3.1.6 1430 AXIAL POWER SHAPING ROD (APSR) Alignment Limits More than one APSR inoperable or not aligned within its limits.

3.6.10 1431 Hydrogen Ignition System (HIS) (Ice Condenser)

Two HIS trains inoperable.

More than one containment region with no operable hydrogen igniter.

3.7.2 1430 1431 1432 Main Steam Isolation Valves (MSIVs)

More than one MSIV inoperable in Mode 1.

3.8.4 1430 1431 1432 1433 1434 DC Sources - Operating Two DC electrical power subsystems inoperable.

2.3. Reason for the Proposed Change The existing LCO 3.0.3 requires a rapid plant shutdown regardless of the risk significance of the plant condition. The NRC has encouraged licensees to use risk information where practical to reduce unnecessary conservatism associated with current regulatory requirements. The proposed change requires a licensee to assess the risk significance of the degradation that led to entry into LCO 3.0.3, to take the appropriate risk management actions, and to shut down the plant in a time frame commensurate with the plant risk.

Historical information has shown that about half of the plant shutdowns initiated under LCO 3.0.3 could be avoided if licensees had additional time to resolve the condition or obtain

TSTF-585, Rev. 4 Page 5 relief from the NRC. While reactor operators are trained to perform a rapid plant shutdown, moving from full power to cold shutdown is a major plant evolution that exercises an array of plant equipment and procedures. Most TS-required equipment is in standby, and its inoperability does not threaten stable plant operation. Therefore, maneuvering the plant through a rapid shutdown transient may be unwarranted for a limited period of time if plant risk is determined to be acceptable and the appropriate risk management actions are implemented.

2.4. Description of the Proposed Change The proposed change revises LCO 3.0.3 to require a risk assessment to be performed and the appropriate risk management actions to be implemented within six hours of entry into LCO 3.0.3. This requirement replaces the existing one-hour time to prepare for a plant shutdown in LCO 3.0.3. If risk is assessed and managed and deemed to be acceptable, operation may continue for a total of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entry into LCO 3.0.3 (that is, eighteen hours after the period permitted for the risk assessment.) At the end of that period, if the plant is still in LCO 3.0.3, initiation of a shutdown is required. If the risk is determined to not be acceptable for continuing plant operation, a plant shutdown must be initiated at the end of the six-hour period provided for the risk assessment. The proposed change to LCO 3.0.3 does not alter the required times to enter lower Modes once a shutdown is initiated under LCO 3.0.3.

The following changes are proposed to LCO 3.0.3 (additions are in italics, deletions are struck through):

PWR TS LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 3 within 7 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ,

b.

MODE 4 within 13 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and

c.

MODE 5 within 37 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or

TSTF-585, Rev. 4 Page 6 entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b.

MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

BWR TS LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 2 within [7 30] hours,

b.

MODE 3 within 13 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and

c.

MODE 4 within 37 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

TSTF-585, Rev. 4 Page 7

a.

MODE 2 within [12] hours,

b.

MODE 3 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 4 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

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

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 6 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to a plant specific time.

Before the time can be changed, plant specific data must be provided to support the extended time.

The Reviewer's Note and the brackets around the time to enter Mode 2 only appear in NUREG-1433. As noted previously, the Mode 2 entry requirement and the Reviewer's Note were removed by TSTF-597.

Other Proposed Changes TS 3.8.9 in NUREG-1430 through NUREG-1434, "Distribution Systems - Operating," is revised to replace a requirement to enter LCO 3.0.3 immediately with a requirement to shut down the plant.

NUREG-1430, NUREG-1431, NUREG-1432 Condition E, "Two or more electrical power distribution subsystems inoperable that result in a loss of safety function," Required Action E.1, "Enter LCO 3.0.3," is replaced with Required Action E.1, "Be in MODE 3," with a Completion Time of six hours, and Required Action E.2, "Be in MODE 5," with a Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

NUREG-1433 and NUREG-1434 Condition F, "Two or more electrical power distribution subsystems inoperable that result in a loss of safety function," Required Action F.1, "Enter LCO 3.0.3," is replaced with Required Action F.1, "Be in MODE 3," with a Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and Required Action F.2, "Be in MODE 4," with a Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

TSTF-585, Rev. 4 Page 8 TS 3.1.6 in NUREG-1430, "AXIAL POWER SHAPING ROD (APSR) Alignment Limits," does not contain a condition for more than one APSR inoperable or not aligned within its limits.

Existing Condition B, "Required Action and associated Completion Time not met," which requires a plant shutdown, is revised to add a new Condition joined with a logical OR which states, "Two or more APSRs inoperable, not aligned within its limits, or both."

TS 3.6.10 in NUREG-1431, "Hydrogen Ignition System (HIS) (Ice Condenser)," does not contain a condition for both HIS trains inoperable or for more than one containment region with no operable hydrogen ignitor. Existing Condition C, "Required Action and associated Completion Time not met," which requires a plant shutdown, is revised to add two new Conditions, each joined with a logical OR which state, "Both HIS trains inoperable," and "More than one containment region with no OPERABLE hydrogen ignitor."

TS 3.7.2 in NUREG-1430, NUREG-1431, and NUREG-1432, "Main Steam Isolation Valves (MSIVs)," does not contain a condition for more than one MSIV inoperable while in Mode 1.

Existing Condition C provides Required Actions for one or more MSIVs inoperable in Mode 2 or 3. Existing Condition B, "Required Action and associated Completion Time of Condition A not met," which requires being in Mode 2 within six hours, is revised to add a new Condition joined with a logical OR which states, "More than one MSIV inoperable in MODE 1."

TS 3.8.4 in NUREG-1430 through NUREG-1434, "Distribution Systems - Operating," does not contain a condition for more than one DC subsystem inoperable (called "station service DC subsystems" in NUREG-1433 and "Division 1 and 2" DC subsystems in NUREG-1434.). A new Condition E is added for the condition of both DC electrical power subsystems inoperable. New Required Action E.1 directs being in Mode 3 in six hours in NUREG-1430 through NUREG-1432 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in NUREG-1433 and NUREG-1434. New Required Action E.2 directs being in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in NUREG-1430 through NUREG 1432 and to be in Mode 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in NUREG-1433 and NUREG-1434.

The TS Bases are revised to reflect these changes.

Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36, states, "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." A licensee may make changes to the TS Bases without prior NRC review and approval in accordance with the Technical Specifications Bases Control Program. The proposed TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132). Therefore, the Bases changes are provided for information, and approval of the Bases is not requested.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

TSTF-585, Rev. 4 Page 9

3. TECHNICAL EVALUATION The proposed change revises the TS to require a risk assessment to be performed, and the appropriate risk management actions to be implemented, within six hours of entering LCO 3.0.3.

This requirement replaces the current one-hour period provided to prepare for a shutdown. The plant conditions that may result in entering LCO 3.0.3 have differing levels of risk significance.

Unlike the current one size fits all approach in the current LCO 3.0.3, the proposed change requires risk to be assessed and the appropriate risk management actions to be implemented, and the timing of the subsequent plant shutdown is informed by the risk assessment. If the risk assessment determines that continuing plant operation is acceptable, the entry into LCO 3.0.3 was not planned, and the appropriate risk management actions have been implemented, initiation of a plant shutdown is required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entering LCO 3.0.3. Otherwise, initiation of a plant shutdown is required within six hours of entering LCO 3.0.3. The proposed change does not alter the times permitted to enter lower Modes once a shutdown is initiated.

The proposed change also revises several specifications to require a plant shutdown instead of explicitly or implicitly requiring entry into LCO 3.0.3. This has no practical effect on plant operation or safety except that the existing hour to prepare for a shutdown in LCO 3.0.3 is not incorporated into the revised TS Actions. This change is more restrictive, but maintaining the allowance of one hour was deemed to be less valuable than maintaining consistency within the TS given the small likelihood that the Actions would be entered.

3.1. LCO 3.0.3 Change Overview 3.1.1. The Proposed Change is Consistent with the Regulations Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.36(c)(2), "Limiting Conditions for Operation," states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by providing a requirement to shut down the reactor if an LCO is not met and the TS does not provide any other remedial action. 10 CFR 50.36(c)(2) does not specify a timeframe for a licensee to shut down the reactor if an LCO is not met. The NRC has found it consistent with 10 CFR 50.36 for the current plant TS to contain a one-hour delay before initiating a plant shutdown. Since the length of the delay is not specified in the regulations, the proposed 6-hour period to assess risk, and the potential for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before initiating a plant shutdown is also consistent with 10 CFR 50.36(c)(2).

The proposed changes to incorporate Actions to initiate a shutdown instead of explicit or implicit entry into LCO 3.0.3 does not change the requirement to shut down the plant. Therefore, these changes are also consistent with 10 CFR 50.36(c)(2).

3.1.2. The Proposed Change Improves Plant Safety Nuclear plant operators are trained to perform a rapid plant shutdown and practice such shutdowns in plant simulators but are rarely called on to do so in the plant. Most TS-required plant shutdowns are preceded by an Action that provides time to restore compliance and TS-required immediate plant shutdowns are rare. A review of ten years of Licensee Event

TSTF-585, Rev. 4 Page 10 Reports (LERs) (2010 - 2020) identified 52 immediate plant shutdowns that were required by the TS over approximately 1000 reactor-years of operation (i.e., approximately one per 20 reactor-years). As a result, immediate plant shutdowns are considered to be infrequent evolutions. Licensees typically implement additional administrative requirements to minimize the risk from infrequent evolutions, but the abbreviated time to initiate a shutdown provided by LCO 3.0.3 may not provide time to implement those precautions.

A plant shutdown under LCO 3.0.3 is also time-critical in that a major plant evolution must be initiated within one hour. A TS-required immediate plant shutdown includes many activities, such as stopping maintenance or testing and restoring systems, or planning for a shutdown with unavailable systems. Human performance studies indicate that time-critical actions are more error prone and providing additional time to initiate a plant shutdown under LCO 3.0.3 could relieve time pressure and reduce the risk of human error.

The NRC's Notice of Enforcement Discretion guidance (NRC Enforcement Manual, Appendix F, "Notices of Enforcement Discretion,") recognizes that a plant shutdown is not always the safest course of action:

The NRC has historically recognized that the two safest modes for operating a nuclear power plant are either Mode 5 (shut down) or Mode 1 (operating at power). Transitions between these two modes may introduce situations or configurations that involve an increase in risk. The NRC expects its licensees to comply with all applicable requirements (i.e., regulations, license conditions, etc.). However, circumstances may arise at an operating NPP where compliance with a TS LCO or a license condition would result in an unnecessary transient without a corresponding health and safety benefit; or a situation may exist where potential radiological or other hazards of continued operation must be balanced against public health and safety or common defense and security.

A comparison of Emergency Notification System (ENS) data to LER data was performed examining the ten-year period of 2010 - 2020. An ENS notification is required when a plant shutdown required by the TS is initiated. An LER is required when a plant shutdown required by the TS is completed. The review determined that only about half of the plant shutdowns initiated under LCO 3.0.3 resulted in a shutdown. This indicates that if licensees had additional time to resolve the condition, the plant transient associated with initiating a plant shutdown could have been avoided.

The goal of the proposed change is to improve plant safety by requiring an assessment of the risk of continuing plant operation to determine whether an immediate shutdown is appropriate or if providing additional time that may avoid an unwarranted plant transient is justified.

The proposed change also revises certain TS Actions to require a plant shutdown instead of invoking LCO 3.0.3. These revised Actions are applicable in conditions which would not warrant additional time.

TSTF-585, Rev. 4 Page 11 3.1.3. The Proposed Change Leverages Existing Risk Management Tools 3.1.3.1. 10 CFR 50.65(a)(4)

The proposed change requires that risk be assessed and managed when LCO 3.0.3 is entered.

The requirement to assess and manage risk has previously been added to:

LCO 3.0.4 (Mode changes),

LCO 3.0.8 (Nonfunctional Snubbers),

LCO 3.0.9 (Nonfunctional Barriers), and

SR 3.0.3 (Missed Surveillances).

In all of these cases, risk is assessed using the existing 10 CFR 50.65(a)(4) (i.e., the Maintenance Rule) tools, which have been in use for over 20 years and are readily available to operators. The NRC's approval of these changes and the TS Bases require the risk assessments to be conducted using the procedures and guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which is endorsed by NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These tools are used to reduce the likelihood of initiating events, reduce the likelihood of the unavailability of redundant trains, and increase the likelihood of successful operator actions in response to an initiating event. The risk assessment must consider all inoperable TS equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The same requirements are imposed by the proposed change.

Section 11 of NUMARC 93-01 provides guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. Assessing the risk means using a risk-informed process to evaluate the overall contribution to risk as a result of inoperable equipment. Managing the risk also means providing plant personnel with proper awareness of the risk and taking actions as appropriate to control the risk. The process for conducting the risk assessments and using the result of the assessment in plant decisionmaking is proceduralized and denotes responsibilities and processes for conducting the assessment for cases when the plant configuration is not covered by the normal assessment tool.

In the operating Modes in which LCO 3.0.3 is applicable, the risk assessment considers the impact on the key plant safety functions that ensure the integrity of the reactor coolant pressure boundary, ensure the capability to shut down and maintain the reactor in a safe shutdown condition, and ensure the capability to prevent or mitigate the consequences of accidents that could result in potentially significant offsite exposures.

The risk assessment considers factors such as:

Technical specifications requirements;

TSTF-585, Rev. 4 Page 12

The degree of redundancy available for performance of the safety function(s) served by the inoperable equipment;

The duration of the condition;

The likelihood of an initiating event or accident that would require the performance of the affected safety function;

The likelihood that the inoperable equipment will significantly increase the frequency of a risk-significant initiating event;

Component and system dependencies that are affected; and

Significant performance issues for the in-service redundant SSCs.

NUMARC 93-01, Section 11.3.2, "General Guidance for the Assessment - Power Operations and Shutdown," also addresses the evaluation of emergent conditions, such as those leading to entry into LCO 3.0.3. The risk assessment must consider emergent conditions, such as inoperable equipment due to failures, or significant changes in external conditions (weather, offsite power availability). The risk assessment must also consider internal events, internal floods, and internal fires.

Risk management actions include planning and conducting plant activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, and actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures).

Risk assessment and risk management actions consider the activities required to restore the inoperable equipment, such as jumpering terminals, lifting leads, placing temporary lead shielding on pipes and equipment, removal of barriers, and use of temporary blocks, bypasses, scaffolding and supports.

3.1.3.2. NEI 18-10 Some licensees use NEI 18-10, "Monitoring the Effectiveness of Nuclear Power Plant Maintenance," as guidance in implementing 10 CFR 50.65 (i.e., the Maintenance Rule) in lieu of NUMARC 93-01. The primary difference between NEI 18-10 and NUMARC 93-01 is in the implementation of 10 CFR 50.65(a)(2), which governs which systems are subject to preventative maintenance programs. However, the risk assessment performed to support the existing and proposed TS includes all inoperable TS equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. Therefore, the use of NEI 18-10 has no effect on the applicability of the proposed change.

NEI 18-10, Section 11, "(A)(4) Assessment," was copied from Section 11 of NUMARC 93-01 without change. Therefore, it is accurate to state that the risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, which endorses the guidance in Section 11 of NUMARC 93-01, regardless of whether the licensee is following NUMARC 93-01 or NEI 18-10.

TSTF-585, Rev. 4 Page 13 3.1.3.3. FLEX and Other Mitigating Strategies In response to the accident at Fukushima Dai-ichi, the NRC issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The Order required licensees to implement diverse and flexible mitigation strategies, known as FLEX, that will increase defense-in-depth for beyond-design-basis scenarios.

As described in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, FLEX consists of:

Both plant and FLEX equipment that provides means of obtaining power and water to maintain or restore key safety functions for all reactors at a site;

Reasonable staging and protection of FLEX equipment from beyond-design-basis external events applicable to a site;

Procedures and guidance to implement FLEX strategies; and

Programmatic controls that assure the continued viability and reliability of the FLEX strategies.

Note that the FLEX strategies are focused on maintaining or restoring key plant safety functions and are not tied to any specific damage state or mechanistic assessment of external events.

NEI 16-06, Crediting Mitigating Strategies in Risk-Informed Decision Making, provides guidance on the use of plant mitigating strategies in risk-informed decision making, such as Maintenance Rule risk assessments and mitigating actions. These mitigating strategies employ plant responses that utilize portable equipment to restore or maintain various safety functions during beyond design basis conditions and the loss of permanently installed plant equipment.

Examples of these strategies include FLEX and may also include other mitigating strategies as discussed in NRC Regulatory Issue Summary (RIS) 2008-15, NRC Staff Position on Crediting Mitigating Strategies Implemented in Response to Security Orders in Risk-Informed Licensing Actions and in the Significance Determination Process.

As part of their 10 CFR 50.65(a)(4) risk assessment process, licensees may consider FLEX and other mitigating strategies when choosing risk management actions and assessing the risk associated with continuing plant operation while in LCO 3.0.3.

3.1.3.4. Support for the Commission's Policy Statement on Technical Specifications and Strategic Plan The Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132, July 22, 1993), states, "as a part of the Commission's ongoing program of improving Technical Specifications, it will continue to consider methods to make better use of risk and reliability information for defining future generic Technical Specification requirements." The proposed change supports that policy.

TSTF-585, Rev. 4 Page 14 The proposed change also supports the Commission's Strategic Plan for 2022-2026 3.

Strategy 1.1.1, is to, "Promote risk-informed decisionmaking to result in effective and efficient oversight, rulemaking, and licensing and certification activities." Strategy 1.2.1 is to, "Maintain and further risk-inform the current regulatory framework using information gained from operating experience, lessons learned, external and internal assessments, technology advances, research activities, and changes in the threat environment." The TS are the principle regulatory framework for ensuring safe plant operation. Applying risk insights to LCO 3.0.3 will be a significant step in pursuing the Commission's strategy.

In summary, the proposed change is acceptable because 1) it is consistent with the regulations, 2) it improves plant safety by replacing an arbitrary shutdown requirement with a risk-informed assessment to determine a more appropriate course of action, 3) it leverages the established Maintenance Rule risk assessment tools, which have been in use and reviewed by the NRC for decades, and 4) it supports the Commission's policy and strategic plan by promoting the use of risk insights in operational decisionmaking.

3.2. LCO 3.0.3 Detailed Justification 3.2.1. Time to Assess and Manage Risk and Implement Risk Management Actions The proposed change adds a new requirement to LCO 3.0.3 to perform a risk assessment and implement the appropriate risk management actions. This new requirement is applicable regardless of any intent to defer a plant shutdown if the risk assessment determines that continuing operation is acceptable. The proposed change provides six hours to perform the risk assessment and implement the appropriate risk management actions and replaces the current one-hour allowance in LCO 3.0.3 to prepare for a plant shutdown. The six-hour period is considered appropriate because:

All licensees have computer software that can calculate plant risk based on the plant configuration used to implement 10 CFR 50.65(a)(4). The time to calculate the risk will vary depending on the software, hardware, and the complexity of the plant condition. It may be necessary to engage the licensee's Probabilistic Risk Assessment (PRA) staff in order to determine the quantitative or qualitative risk. These activities may take from one to several hours.

The time required to implement risk management actions, such as briefing the operating staff, protecting equipment, or pre-staging FLEX equipment, varies and may require additional staff.

Taken together, a six-hour period to perform the risk assessment and implement the appropriate risk management actions is reasonable.

3 NUREG-1614, "Strategic Plan," Volume 8.

TSTF-585, Rev. 4 Page 15 Extending the current one-hour delay period to initiate a plant shutdown to six hours is acceptable because the one-hour delay was arbitrary and did not consider the risk associated with a plant shutdown. The proposed six-hour delay provides time to assess the risk significance of the plant conditions and to determine the appropriate actions to take to minimize the impact on plant safety. This change provides greater protection of public health and safety by not requiring a shutdown with inoperable equipment when safer options may be available.

As an added layer of defense in addition to the protection provided by the TS requirements, licensed operators are trained to take conservative actions to protect the public health and safety and the plant. Each licensee maintains Alarm Response Procedures, Abnormal Operating Procedures (AOPs), and Emergency Operating Procedures (EOPs). These procedures provide the operator guidance on how to verify the adequacy of, restore, or maintain critical safety functions in order to keep the plant in a safe condition such that public health and safety will not be endangered. Should plant conditions warrant immediate action to ensure safety or if continued safe operation of the plant is uncertain, licensed operators are directed and trained to take appropriate action regardless of allowances in the TS.

3.2.2. Plant Operation May Continue if Risk is Acceptable One criterion associated with the proposed 24-hour provision from entry into LCO 3.0.3 is that a risk assessment determines that the risk of continuing plant operation is acceptable. Just as the Maintenance Rule risk assessment tools will be used to determine risk, the Maintenance Rule guidance is used to establish the limits for continuing plant operation.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. These limits are consistent with the NUMARC 93-01, Section 11.3.7.2, guidance on configurations that should not normally be entered voluntarily. Consistent with the NUMARC guidance, non-quantifiable factors must also be assessed.

In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation.

The impact on plant risk is evaluated from the baseline, zero maintenance risk.

For multiple unit sites with shared systems, the risk assessment should consider any cross-unit effects.

Whenever practicable, the Maintenance Rule risk assessment tools will be used to determine a quantitative value for risk. It may not be practicable to determine a quantitative value for risk if the inoperable systems are not modeled in the plant's PRA or if the inoperable systems have no effect on core damage, such as Reactor Coolant System Leakage Detection Instrumentation. In this case, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continuing operation for 24-hours from entry into LCO 3.0.3 is acceptable.

TSTF-585, Rev. 4 Page 16 Assessment and management of risk requires knowing the likely cause of the failures or variables outside their limits that resulted in LCO 3.0.3 entry in order to assess the risk and to take the appropriate risk management actions. A formal cause or apparent cause evaluation is not required because of the limited time available; however, the likely cause should be known. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

The assessment of plant risk is continuous while the plant is utilizing the 24-hour continuing plant operation period, consistent with the requirements of the Maintenance Rule. If the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action shall be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

The proposed change is acceptable because the use of NRC-endorsed guidance, limitations, and conditions on the risk assessment will ensure that the plant risk is adequately determined when considering whether continuing plant operation is appropriate.

3.2.3. Plant Operation May Continue if Appropriate Risk Management Actions are Implemented The term appropriate risk management actions means those risk management actions that are implemented in accordance with the licensee's Maintenance Rule procedures and are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

Risk management actions are currently required by two TS provisions in addition to the Maintenance Rule:

LCO 3.0.4.b requires the establishment of risk management actions, if appropriate.

The Risk Informed Completion Time Program requires the establishment of risk management actions at certain risk thresholds.

NUMARC 93-01, Section 11.3.7.5, Risk Management Actions, states:

Risk management actions should be considered for configurations that result in a minimal increase from the plants baseline risk. [T]he benefits of these actions are generally not quantifiable. These actions are aimed at providing increased risk awareness of appropriate plant personnel, providing more rigorous planning and control of the activity, and taking measures to control the duration of the increased risk, and the magnitude of the increased risk.

Examples of risk management actions that may be appropriate for an entry into LCO 3.0.3 are:

Conduct pre-job briefing of maintenance personnel, emphasizing risk aspects of plant evolutions.

Identify return-to-service priorities.

TSTF-585, Rev. 4 Page 17

Identify important remain-in-service priorities.

Place warning signs or placards in the entry ways to protect other in-service risk significant equipment.

Pre-stage required parts and materials accounting for likely contingencies.

Perform maintenance around the clock rather than day-shift only.

Establish contingency plan to restore key out-of-service equipment rapidly if and when needed.

Postpone plant activities, if appropriate, to maintain or reduce risk levels.

Minimize other work in areas that could affect related initiating events (e.g., reactor protection system (RPS) equipment areas, switchyard, diesel generator (DG) rooms, switchgear rooms) to decrease the frequency of initiating events that are mitigated by the safety function served by the out-of-service SSC.

Identify remain-in-service priorities and minimize work in areas that could affect other redundant systems (e.g., SI & RHR rooms, auxiliary feedwater pump rooms), such that there is enhanced likelihood of the availability of the safety functions at issue served by the SSCs in those areas.

Establish alternate success paths (provided by either safety or non-safety related equipment) for performing the safety function of the out-of-service SSC.

Establish other compensatory measures as appropriate.

Return equipment to service to reduce risk levels.

Install/connect temporary equipment to substitute for permanent equipment that is out of service.

The proposed change is acceptable because the risk management actions will address non-quantifiable factors and other aspects of the plant configuration that may not be fully addressed by the quantitative risk assessment to ensure that continuing plant operation for a limited time is appropriate.

3.2.4. Plant Operation May Continue if the LCO 3.0.3 Entry is Unplanned The requirement to initiate actions to shut down the plant within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3 may not be used if the entry into LCO 3.0.3 is planned. For example, if Train A of a two-train system is inoperable due to maintenance, the licensee may not plan to make Train B inoperable such that LCO 3.0.3 is applicable and then apply LCO 3.0.3 to defer initiation of a shutdown. However, if Train A of a two-train system is inoperable for maintenance and emergent conditions result in Train B being inoperable causing entry into LCO 3.0.3, the 24-hour allowance may be used as long as the risk assessment determines continuing operations is acceptable and appropriate risk management actions are implemented.

TSTF-585, Rev. 4 Page 18 As stated in the current TS Bases, planned entry into LCO 3.0.3 should be avoided. In a 1987 memorandum from the NRC Region V Administrator to the NRC Director of the Office of Nuclear Reactor Regulation5, the Administrator stated:

Region V recognizes that occasional entry into LCO 3.0.3 for surveillance or maintenance purposes may be appropriate, however, this activity should be well thought-out in advance and strictly controlled by management oversight and appropriate procedures.

This guidance was expanded in TSTF-565, Revision 1, "Revise the LCO 3.0.2 and LCO 3.0.3 Bases," which was accepted by the NRC on December 31, 2018 (ADAMS Accession No. ML18284A377). As stated in the NRC's approval letter:

The proposed STS Bases for LCO 3.0.3 in Traveler TSTF-565, Revision 1, continue to discourage but not prohibit voluntary removal of redundant systems or components from service. The revised bases include the following: 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). Therefore, when an intentional entry is made, provisions in the Maintenance Rule provide a defined process to assess and manage any increase in risk that may result from such intentional entry. In addition, TS Actions provide necessary and appropriate measures given the LCO conditions, to maintain the plant in a safe condition.

The proposed changes to LCO 3.0.3 and the LCO 3.0.3 Bases in this traveler are acceptable because they are consistent with the justification in TSTF-565. Planned use of the extended period of operation is not permitted as the existing TS LCOs and Completion Times already consider the need for planned entries.

3.2.5. Basis for the 24-Hour Period The proposed 24-hour period to remain in LCO 3.0.3 is based on the expected plant actions in this condition. On entry into LCO 3.0.3, a licensee will typically be pursuing four activities in parallel:

Performance of a risk assessment and implementation of appropriate risk management actions;

Preparing for an orderly plant shutdown; 5 Letter from J. B. Martin, Regional Administrator, Region V, to Harold R. Denton, Director, Office of Nuclear Reactor Regulation, "Intentional Entry into Technical Specification Limiting Condition for Operation 3.0.3," dated March 18, 1987. NRC ADAMS Accession No. ML20245A620)

TSTF-585, Rev. 4 Page 19

Working to restore equipment to operable status or parameters to within limits in order to exit LCO 3.0.3; or

Evaluating whether to request relief from the NRC.

If within the first six hours the risk assessment determines that continuing operation is acceptable, appropriate risk management actions have been implemented, and the entry into LCO 3.0.3 was unplanned, licensees may pursue the remaining actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. The 24-hour period is based on pursuing these goals.

Preparing for an orderly plant shutdown may include many activities, such as:

Bring an additional operating crew on site to support the shutdown, which considers that the LCO 3.0.3 entry may occur on a weekend, holiday, or during a night shift when there may be less staff on site.

Bring in additional site technical and maintenance support staff to secure any station maintenance in progress, restore any inoperable components necessary for shutdown, or address any maintenance issues that arise during shutdown.

Bring in simulator staff to support simulator exercises of a shutdown with the inoperable equipment that led to entry into LCO 3.0.3. The simulator staff must familiarize themselves with the situation and prepare training scenarios.

Conduct simulator training to prepare the crew for the shutdown considering the current plant condition, including the inoperable equipment. This may include turn over to another shift crew to staff the control room during training.

Perform just-in-time procedure reviews to prepare for the shutdown. Additional operating staff may be needed to allow the shutdown shift to perform the reviews.

Coordinate with the transmission load dispatcher for power requirements with the station offline.

Therefore, if the proposed conditions are met, providing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 to prepare for an orderly shutdown is reasonable.

The licensee should have a reasonable scope and schedule for restoring compliance such that LCO 3.0.3 is no longer applicable. However, it is not required that the schedule be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or less, as the licensee may be pursuing regulatory relief or an orderly shutdown in addition to working to restore compliance with the LCOs.

In parallel with repairs and preparing for an orderly shutdown, the licensee may request regulatory relief to provide additional time to repair the condition. The NRC Enforcement Manual, Appendix F, "Notices of Enforcement Discretion," describes the process for considering enforcement discretion. While not impossible, it is unlikely that a licensee could provide the requested information and for the NRC staff to have sufficient time to consider the request and render a decision under the current LCO 3.0.3 one-hour period before a plant shutdown is

TSTF-585, Rev. 4 Page 20 initiated. However, if the proposed conditions are satisfied, the proposed 24-hour period would be sufficient for the licensee to request and for the NRC to consider enforcement discretion or an emergency license amendment under the provisions of 10 CFR 50.91(a)(5). Until such relief is granted, the licensee must follow their TS.

The proposed 24-hour period of continued operation is a reasonable period to prepare for a shutdown, pursue relief (if justified) from the NRC, or to perform repairs to exit LCO 3.0.3, provided that the requirements of LCO 3.0.3 are met.

3.3. LCO 3.0.3 Editorial Changes The revision to LCO 3.0.3 required a change to the time to be in the listed Modes. One hour is subtracted from each time because the existing one-hour delay time is removed and six or twenty-four hours are added to the times to reflect the time provided to perform the risk assessment and, if justified, the additional time for continuing plant operation. All times are based on the entry into LCO 3.0.3.

The penultimate paragraph of LCO 3.0.3 states, "Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required." This is revised to state, "If corrective measures are completed, then " as an editorial improvement.

The LCO 3.0.3 editorial changes are acceptable because they are conforming changes necessary to implement the revised requirements.

3.4. Other TS Changes 3.4.1. Other TS Evaluation The industry evaluated the STS NUREGs and identified the Actions that invoked LCO 3.0.3 explicitly and also identified specifications that lacked Actions for obvious failures to meet the LCO, such as not providing an Action for two inoperable trains in specifications that require two trains to be operable. Each Action or specification was then examined, considering factors such as:

Could the Condition affect safe plant operation assuming no other failures or accidents?

Could the Condition be assessed for its risk impact?

Could the Condition be entered for failures that would not significantly degrade the ability of the system to perform its primary function?

Are there proceduralized actions that can be taken to diminish the impact of the failure?

Would an immediate plant shutdown be complicated by the failure?

It was determined that no changes are needed for most specifications and the proposed revision to LCO 3.0.3 would be appropriate if the conditions for use are met. For example:

TSTF-585, Rev. 4 Page 21

The "Emergency Core Cooling System - Operating" specification Actions for PWRs requires entering LCO 3.0.3 when less than 100% of the ECCS flow equivalent to a single operable train is available. For BWRs, LCO 3.0.3 entry is required for several combinations of inoperable equipment that would prevent the ECCS from performing its required function. However, the proposed LCO 3.0.3 is appropriate for this condition.

At most PWR and BWR plants, the low pressure ECCS components are also used for decay heat removal during shutdown. Requiring an immediate plant shutdown to a condition that could require the use of an inoperable decay heat removal system may be unwarranted. Also, high pressure injection is typically a low-risk system (risk informed Completion Times typically greater than 30 days) and time to diagnose and potentially correct inoperabilities should be permitted.

The "AC Sources - Operating" specification requires entering LCO 3.0.3 when three or more required AC sources are inoperable. Using the proposed LCO 3.0.3 if the conditions are met is appropriate for this condition. If both offsite circuits are inoperable, a plant trip will likely render LCO 3.0.3 entry moot. However, if the unit continues to operate in this TS condition (for example, if two DGs and one offsite circuit are inoperable), requiring an immediate plant shutdown and removal of the main generator as a power source should be avoided. If plant risk is assessed and managed, permitting additional time to restore sufficient capability to exit LCO 3.0.3 before initiating a shutdown is reasonable. Note that the proposed change does not alter the existing TS Actions that require restoring at least one of two inoperable DGs within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . If an offsite circuit and DG are both inoperable, the TS requires one to be restored within 12-hours. As discussed in TS Example 1.3-2, these Actions continue and effectively limit the application of the proposed change to LCO 3.0.3.

Many TS instrumentation functions do not include a Condition for all required channels for a function being inoperable. Using the proposed LCO 3.0.3 if the conditions are met is appropriate for these conditions. Disturbing the plant when instrumentation is inoperable could result in a reactor trip or inadvertent actuation. Moreover, there are usually redundant and diverse ways of determining important plant parameters and most initiation functions have multiple methods of achieving the goal. Most automatic functions can be manually performed by an operator using existing procedures.

However, if the plant is in an unknown state, plant operators are trained to take conservative action to protect plant safety, such as manually initiating a reactor trip.

Lastly, if a channel is out of service for testing or maintenance, it usually can be restored, and the condition exited.

The evaluation identified some specifications that should be revised to eliminate an explicit or implicit entry into LCO 3.0.3 and to instead require a plant shutdown or other appropriate actions.

TSTF-585, Rev. 4 Page 22 3.4.2. Other TS Changes 3.4.2.1. NUREG-1430, TS 3.1.6, "AXIAL POWER SHAPING ROD (APSR) Alignment Limits" The specification requires each APSR to be operable and aligned with its group average height.

There is no TS Action for more than one inoperable APSR or more than one APSR not aligned with the group average height. More than one misaligned APSR may produce unacceptable power peaking factors and linear heat generation rates. A risk assessment cannot be performed for reactor parameters. Therefore, the implicit LCO 3.0.3 entry is replaced with a requirement to shut down the reactor by modifying the existing default Action to be in Mode 3 within six hours with an additional Condition applicable when two or more APSRs are inoperable or not aligned within the limits.

Revising the Actions when more than one APSR is misaligned to require a plant shutdown instead of entering LCO 3.0.3 is appropriate because the risk associated with APSR misalignment cannot be quantitatively or qualitatively evaluated in accordance with the proposed LCO 3.0.3.

3.4.2.2. NUREG-1431, TS 3.6.10, "Hydrogen Ignition System (HIS)"

The specification is applicable to plants with an ice condenser containment design. Two HIS trains are required to be operable. There are no Conditions for both HIS trains inoperable or for more than one containment region with no operable hydrogen ignitor. Ice condenser plants are vulnerable to hydrogen ignition in post-accident environments because of their small containment volume. The unavailability of both HIS trains or of the ignitors in more than one compartment could lead to hydrogen buildup and ignition, potentially overpressurizing the containment or damaging equipment. Therefore, the implicit LCO 3.0.3 entry is replaced with a requirement to shut down the reactor by modifying the existing default Action to be in Mode 3 within six hours with an additional Condition applicable when both HIS trains are inoperable, or if there is more than one containment region with no operable hydrogen ignitor.

Revising the Actions to require a plant shutdown when the HIS cannot perform its function is appropriate because in the event of an accident, the condition could result in damage to the containment.

3.4.2.3. NUREG-1430, NUREG-1431, and NUREG-1432, TS 3.7.2, "Main Steam Isolation Valves (MSIVs)"

The specifications require the MSIV on each steam line to be operable in Mode 1, and in Modes 2 and 3 except when all MSIVs are closed. There is an Action for one MSIV inoperable in Mode 1 and an Action for one or more MSIVs inoperable in Mode 2 or 3, but there is no Action for more than one MSIV inoperable in Mode 1. The MSIVs are the primary mitigation mechanism for a number of events, such as a steam generator tube rupture, a high-energy line break inside containment, a main steam line break outside of the containment, and a feedwater line break. Inoperability of more than one MSIV, particularly in plants with only two or three main steam lines, would have a significant impact on the plant's ability to respond to these events. Therefore, the implicit LCO 3.0.3 entry is replaced with a requirement to exit Mode 1 by

TSTF-585, Rev. 4 Page 23 modifying the existing default Action to be in Mode 2 within six hours with an additional Condition applicable when more than one MSIV is inoperable while in Mode 1.

Revising the MSIV Actions to require entry into Mode 2 instead of entering LCO 3.0.3 when more than one MSIV is inoperable is appropriate because the revised Actions are consistent with restoring compliance with the LCO.

3.4.2.4. NUREG-1430 through NUREG-1434 TS 3.8.4, "DC Sources - Operating" The specifications require two subsystems or divisions of DC power to be operable. The specification contains an Action for the battery or batteries and battery charger(s) on one subsystem or division inoperable but does not contain an Action for more than one DC electrical power subsystem inoperable. The batteries, along with the inverters, are the uninterruptible power source for the reactor protection and engineered safety feature instrumentation and controls. As most at-power accident analyses assume a loss of normal power and credit the reactor protection and engineered safety feature instrumentation and controls, loss of more than one DC electrical subsystem would have a significant impact on the plant's ability to respond to an accident. Therefore, the implicit LCO 3.0.3 entry is replaced with a new Action with Required Actions to shut down the reactor and exit the Applicability of the specification in the timeframes used in the examples in Section 1.3 of the STS.

The proposed change is appropriate because it protects plant safety by requiring a plant shutdown immediately when power to the reactor protection and engineered safety feature instrumentation and controls is unavailable.

3.4.2.5. NUREG-1430 through NUREG-1434 TS 3.8.9, "Distribution Systems - Operating" The specifications require entry into LCO 3.0.3 when two or more inoperable divisions or subsystems result in a loss of function. Electrical distribution includes AC, DC, and AC Vital Bus systems. When two or more electrical power distribution subsystems are inoperable that result in a loss of safety function, the remaining subsystems are no longer capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition without assuming any additional failures. Therefore, an immediate plant shutdown is warranted. The Required Action to enter LCO 3.0.3 is replaced with Required Actions to shut down the reactor and exit the Applicability of the specification in the timeframes used in the examples in Section 1.3 of the STS. The Required Actions and Completion Times are consistent with the other Actions in the TS and the Examples in TS Section 1.3.

The proposed change is appropriate because it protects plant safety by requiring a plant shutdown immediately when electrical power for the minimum safety functions is unavailable.

3.5. TS Bases Changes The TS Bases are revised to reflect the proposed TS changes. The LCO 3.0.3 Bases discuss the requirement that risk be assessed and managed, and state that the risk assessment must be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160 and Section 11 of NUMARC 93-01, and that the risk assessment must determine that continuing operation is acceptable. Acceptability is based on the guidelines in NUMARC 93-01; that is,

TSTF-585, Rev. 4 Page 24 there should be no more than minimal increase in risk after implementation of risk management actions (i.e., the level determined acceptable during normal work control levels) and that the instantaneous risk is within limits. The model application requires the licensee to confirm that this guidance will be followed. The Bases also discuss the treatment of common cause in the risk assessment and implementation of appropriate risk management actions.

Editorial changes are made to the LCO 3.0.3 Bases to improve consistency and clarity.

LCO 3.0.3 describes three conditions on entry, but the TS Bases combine two of those reasons. The Bases are revised to be consistent with the TS.

The LCO 3.0.3 Bases state, This Specification delineates the time limits for placing the unit 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. While the phrase, within the limits for safe operation, may be correct, it is not one of the conditions given for entering LCO 3.0.3 in the TS and perpetuates a common misunderstanding that LCO 3.0.3 entry may be required for reasons other than those stated in the TS. Therefore, the phrase for safe operation is removed.

The Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors describes the scope and purpose of the STSs Bases. It does so by listing five questions the STSs Bases must address. While the STSs Bases as a whole must address these questions, not every question will be relevant to every change to the STSs Bases.

The first Policy Statement question states that the Bases should identify the 10 CFR 50.36(c)(2)(ii) criterion that applies to the LCO. In the case of LCO 3.0.3, which is a usage rule for the technical specifications, there is no single criterion satisfied by the requirement. Instead, LCO 3.0.3 satisfies the 10 CFR 50.36(c)(2) requirement regarding remedial actions. The other TS changes do not affect LCOs or LCO Bases.

The second Policy Statement question states that the basis for each LCO should be described, i.e., why was it determined to be the lowest functional capability or performance level for the system or component in question necessary for safe operation of the facility and, what are the reasons for the Applicability of the LCO. LCO 3.0.3 is a usage rule and does not provide requirements for specific systems or components. However, the LCO 3.0.3 Bases describes the purpose and applicability of LCO 3.0.3.

The third Policy Statement question states that the Bases for each Action should be described, i.e., why should this remedial action be taken if the associated LCO cannot be met; how does this Action relate to other Actions associated with the LCO; and what justifies continued operation of the system or component at the reduced state from the state specified in the LCO for the allowed time period? The LCO 3.0.3 Bases are expanded to describe the actions required when LCO 3.0.3 is entered and how it justifies continued operation. The Bases of the other affected TS Actions are revised to describe why the Actions are appropriate for the condition.

The fourth and fifth Policy Statement questions are not relevant because the proposed changes do not affect the safety limits or Surveillance Requirements.

TSTF-585, Rev. 4 Page 25 Therefore, the proposed revisions to the STSs Bases are consistent with the Commissions Final Policy Statement and 10 CFR 50.36 because the STS Bases changes adequately address the first, second, and third questions.

3.6. Conclusion The proposed change will enhance plant safety by assessing and managing plant risk when LCO 3.0.3 is entered, thereby avoiding unnecessary plant shutdown transients when the risk is acceptable. This permits time to rectify the condition, prepare for an orderly plant shutdown, or request NRC relief. The proposed change supports continued implementation of the Commissions "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," and satisfies the requirements of 10 CFR 50.36. Additionally, the proposed change supports the NRC's Strategic Plan by promoting risk-informed decisionmaking and further risk-informing the current regulatory framework. The proposed change is acceptable because it will continue to provide reasonable assurance of adequate protection of the health and safety of the public.

4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

TSTF-585, Rev. 4 Page 26 The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls".

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

5. REFERENCES

1) NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

2) Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

3) NEI 18-10, "Monitoring the Effectiveness of Nuclear Power Plant Maintenance."

4) TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement."

5) TSTF-565, Revision 1, "Revise the LCO 3.0.2 and LCO 3.0.3 Bases."

6) NUREG-1614, "Strategic Plan," Volume 8.

TSTF-585, Rev. 4 Model Application

TSTF-585, Rev. 4 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME

[50][52]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-585 revises Limiting Condition for Operation (LCO) 3.0.3 to require assessing and managing plant risk whenever LCO 3.0.3 is entered. If the risk assessment determines that continuing plant operation is acceptable and other conditions are satisfied, 24-hours from entry into LCO 3.0.3 is permitted to initiate a shutdown. Otherwise, initiation of the shutdown is required immediately. The proposed amendment also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line-Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

TSTF-585, Rev. 4 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TITLE, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

2.

Revised Technical Specification Pages

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-585, Rev. 4 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-585 revises Limiting Condition for Operation (LCO) 3.0.3 to require a risk assessment to be performed and appropriate risk management actions to be implemented within six hours. If the risk assessment determines that continuing plant operation is acceptable and other conditions are satisfied, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is permitted to initiate a shutdown. Otherwise, initiation of the shutdown is required immediately. The proposed amendment also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-585 provided to the Technical Specifications Task Force in a letter dated [DATE]. This included a review of the NRC staffs evaluation, as well as the information provided in TSTF-585. [As described herein,]

[LICENSEE] has concluded that the justifications presented in TSTF-585 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

[LICENSEE] confirms Section 11 of NUMARC 93-01 will be used to perform the LCO 3.0.3 risk assessment to determine whether continuing plant operation is acceptable.

[LICENSEE] has reviewed the [PLANT] plant-specific specifications that do not appear in the STS. [LICENSEE] has determined that [none of the] [the following] plant-specific specifications should be revised to require a plant shutdown instead of entering LCO 3.0.3.]

[Describe any additional changes.]

2.2 Variations

((LICENSEE] is not proposing any variations from the TS changes described in TSTF-585 or the applicable parts of the NRC staffs safety evaluation dated [DATE.)) ((LICENSEE] is proposing the following variations from the TS changes described in TSTF-585 or the applicable parts of the NRC staffs safety evaluation: [Describe the variations.))

((LICENSEE] has adopted TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement,"

on [DATE]. TSTF-597 removed the Boiling Water Reactor TS requirement to be in Mode 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months of entering LCO 3.0.3. Adoption of TSTF-597 does not affect the justification or acceptability of TSTF-585.]

TSTF-585, Rev. 4 Page 4

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-585 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-585 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-585 to the [PLANT] TS.]

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-585 was based but are encompassed in the TSTF-585 justification. [Describe differences and why TSTF-585 is still applicable.))

[The [PLANT] TS contain Actions for conditions that are added or modified in the traveler to avoid entry into LCO 3.0.3. They are [describe.] As a result, these traveler changes are not applicable. This does not affect the applicability of the remaining portions of TSTF-585 to the

[PLANT] TS.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-585 revises Limiting Condition for Operation (LCO) 3.0.3 to require a risk assessment to be performed and appropriate risk management actions to be implemented within six hours. If the risk assessment determines that continuing plant operation is acceptable and other conditions are satisfied, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is permitted to initiate a shutdown. Otherwise, initiation of the shutdown is required immediately. The proposed amendment also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No The proposed change revises LCO 3.0.3 to provide additional time before initiating a plant shutdown. The proposed change also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change does not affect the capability of any system to perform a design function as assumed in previously evaluated accidents because the affected systems are inoperable prior to entering LCO 3.0.3 or the Required Actions. The time permitted before initiating a plant shutdown when Technical Specification requirements are not met is not an assumption in any design basis accident or transient. Equipment that is inoperable prior to an analyzed event is not an initiator of any accident previously evaluated. Therefore, the probability of any accident previously evaluated is not affected.

TSTF-585, Rev. 4 Page 5 The consequences of any design basis accident or transient that might occur during the proposed period prior to initiation of a plant shutdown are no different than the consequences of such an event during the current delay period provided by LCO 3.0.3.

The likelihood of malfunction of equipment is not affected as the applicable equipment is inoperable prior to entering LCO 3.0.3 or the Required Actions. As a result, the consequences of previously evaluated accidents are not affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No The proposed change revises LCO 3.0.3 to provide additional time before initiating a plant shutdown. The proposed change also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change only alters the time permitted before initiating a plant shutdown when TS equipment is inoperable, or TS limits are not met. The proposed change does not alter the design function or operation of any equipment because the affected systems are inoperable prior to entering LCO 3.0.3 or the Required Actions. The design basis accidents and transients considered in the updated final safety analysis report (UFSAR) assume that equipment is operable at the beginning of the analysis, and the time permitted to restore inoperable equipment or variables outside of limits is not an assumption in the UFSAR in any design basis accident or transient analyses. Therefore, providing a longer period after entering LCO 3.0.3 before initiating a plant shutdown or adding Required Actions that direct a plant shutdown would not have been considered a new or different design basis accident in the UFSAR if it had been previously identified.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises LCO 3.0.3 to provide additional time before initiating a plant shutdown. The proposed change also revises or adds some TS Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change only alters the time permitted before initiating a plant shutdown when TS equipment is inoperable, or TS limits are not met. The proposed change does not alter any specific values assumed in the design and licensing basis or controlling values of parameters. The proposed change does not alter a design basis or safety limit.

TSTF-585, Rev. 4 Page 6 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, [LICENSEE] concludes that the proposed change presents 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.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 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 surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents 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.

TSTF-585, Rev. 4 Technical Specifications and Bases Changes

LCO Applicability 3.0 Babcock & Wilcox STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 3 within 307 hours0.00355 days 0.0853 hours 5.076058e-4 weeks 1.168135e-4 months ,

b.

MODE 4 within 3613 hours0.0418 days 1.004 hours 0.00597 weeks 0.00137 months , and

c.

MODE 5 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b.

MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

TSTF-585, Rev. 4

LCO Applicability 3.0 Babcock & Wilcox STS 3.0-2 Rev. 5.0 If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

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 (exceptions to this Specification are stated in the individual Specifications); or TSTF-585, Rev. 4

APSR Alignment Limits 3.1.6 Babcock & Wilcox STS 3.1.6-1 Rev. 5.0 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 AXIAL POWER SHAPING ROD (APSR) Alignment Limits LCO 3.1.6 Each APSR shall be OPERABLE and aligned within [6.5]% of its group average height.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One APSR inoperable, not aligned within its limits, or both.

A.1 Perform SR 3.2.3.1.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each APSR movement B. Two or more APSRs inoperable, not aligned within their limits, or both.

OR Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify position of each APSR is within [6.5]% of the group average height.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the TSTF-585, Rev. 4

MSIVs 3.7.2 Babcock & Wilcox STS 3.7.2-1 Rev. 5.0 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 Two MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when all MSIVs are closed [and deactivated].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

[8] hours

[OR In accordance with the Risk Informed Completion Time Program]

B. More than one MSIV inoperable in MODE 1.

OR Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months C. ------------NOTE------------

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

[8] hours Once per 7 days D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months TSTF-585, Rev. 4

DC Sources - Operating 3.8.4 Babcock & Wilcox STS 3.8.4-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and Associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two DC electrical power subsystems inoperable.

E.1 Be in MODE 3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

TSTF-585, Rev. 4

Distribution Systems - Operating 3.8.9 Babcock & Wilcox STS 3.8.9-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC electrical power distribution subsystems inoperable.

C.1 Restore DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

E.1 Be in MODE 3.Enter LCO 3.0.3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Immediately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months TSTF-585, Rev. 4

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-2 Rev. 5.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:

a.

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

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit.; or

c.

Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

TSTF-585, Rev. 4

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-3 Rev. 5.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit 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, a risk assessment addressing inoperable systems and components must be completed and appropriate risk management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk assessment must consider all inoperable equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures). The likely cause of the conditions that resulted in LCO 3.0.3 entry should be understood. A formal cause or apparent cause evaluation is not required because of the limited time available. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. Non-quantifiable factors should also be assessed. In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation. The impact on plant risk is evaluated from the baseline, zero-maintenance, condition.

TSTF-585, Rev. 4

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-4 Rev. 5.0 Whenever practicable, a quantitative value for risk should be determined. If determination of a quantitative value for risk is not practicable, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continued operation for a limited time is acceptable.

If during the 24-hour period the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action must be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

Appropriate risk management actions are implemented in accordance with the Maintenance Rule procedures that are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

If the risk assessment determines that continuing operation is acceptable, that the appropriate risk management actions are implemented, and that entry into LCO 3.0.3 was unplanned, action to shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. It is not necessary for the planned restoration of compliance with the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are available, such as regulatory relief or an orderly shutdown. The 24-hour provision may not be used if the LCO 3.0.3 entry is planned, such as intentionally removing a train from service when the redundant train is inoperable. However, it may be used for emergent conditions that occur in parallel with other planned or unplanned inoperabilities.

The determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

If the risk assessment determines that continuing operation is not acceptable, if the risk assessment was not completed, the appropriate risk management actions were not implemented, or if entry into LCO 3.0.3 was planned, action to shut down the unit must be initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the risk assessment and implement risk management actions.

All times for completing actions and entering MODES are determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time TSTF-585, Rev. 4

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-5 Rev. 5.0 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 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 unit, 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 times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit 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,

b.

The LCO is no longer applicable,

c.

A Condition exists for which the Required Actions have now been performed, or

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.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in MODE 5 when after a shutdown is initiated required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is requiredinitiated, the time limit for entering the next lower MODE applies.

If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a shutdown is initiated, then the time allowed for entering MODE 4 BASES LCO 3.0.3 (continued) is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 4 is not reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is initiated. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, 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 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of TSTF-585, Rev. 4

LCO APPLICABILITY B 3.0 Babcock & Wilcox STS B 3.0-6 Rev. 5.0 LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) 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 unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Fuel Storage Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in 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 unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not 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 following 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 ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard TSTF-585, Rev. 4

APSR Alignment Limits B 3.1.6 Babcock & Wilcox STS B 3.1.6-3 Rev. 5.0 BASES ACTIONS A.1 The ACTIONS described below are required if one APSR is inoperable.

The plant is not allowed to operate with more than one inoperable APSR.

This would require the reactor to be shut down, in accordance with LCO 3.0.3.

An alternate to realigning a single misaligned APSR to the group average position is to align the remainder of the APSR group to the position of the misaligned or inoperable APSR, while maintaining APSR insertion, in accordance with the limits in the COLR. This restores the alignment requirements. Deviations up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will not cause significant xenon redistribution to occur. This alternative assumes the APSR group movement does not cause the limits of LCO 3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," to be exceeded. For this reason, APSR group movement is only practical for instances where small movements of the APSR group are sufficient to re-establish APSR alignment.

The reactor may continue in operation with the APSR misaligned if the limits on AXIAL POWER IMBALANCE are surveilled within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to determine if the AXIAL POWER IMBALANCE is still within limits. Also, since any additional movement of the APSRs may result in additional imbalance, Required Action A.1 also requires the AXIAL POWER IMBALANCE Surveillance to be performed again within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each APSR movement. The required Completion Time of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will not cause significant xenon redistribution to occur.

B.1 The plant must be brought to a MODE in which the LCO does not apply if more than one APSR is inoperable, or is misaligned, or both, or the Required Actions and associated Completion Times cannot be met. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching MODE 3 from RTP in an orderly manner and without challenging plant systems. In MODE 3, APSR group alignment limits are not required because the reactor is not generating THERMAL POWER and excessive local LHRs cannot occur from APSR misalignment.

TSTF-585, Rev. 4

MSIVs B 3.7.2 Babcock & Wilcox STS B 3.7.2-4 Rev. 5.0 BASES ACTIONS (continued)

B.1 If the MSIV cannot be restored to OPERABLE status in accordance with Required Action A.1, or if more than one MSIV is inoperable in MODE 1, the unit must be placed in MODE 2 and the inoperable MSIV(s) closed within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Times are reasonable, based on operating experience, to reach MODE 2.

C.1 and C.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

The [8] hour Completion Time is consistent with that allowed in Condition A.

Inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

D.1 and D.2 If the MSIV cannot be restored to OPERABLE status or closed in the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 Babcock & Wilcox STS B 3.8.4-8 Rev. 5.0 BASES ACTIONS (continued)

D.1 and D.2 If the inoperable DC electrical power subsystem(s) cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. For example, in MODE 4 the turbine driven emergency feedwater pump[s] are available to provide Reactor Coolant System (RCS) cooling via the steam generators utilizing natural circulation.

However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 and E.2 If both DC electrical power subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.4.1 TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 Babcock & Wilcox STS B 3.8.9-7 Rev. 5.0 BASES ACTIONS (continued) results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1and E.2 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the [required] AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

TSTF-585, Rev. 4

LCO Applicability 3.0 Westinghouse STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 3 within 307 hours0.00355 days 0.0853 hours 5.076058e-4 weeks 1.168135e-4 months ,

b.

MODE 4 within 3613 hours0.0418 days 1.004 hours 0.00597 weeks 0.00137 months , and

c.

MODE 5 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b.

MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

TSTF-585, Rev. 4

LCO Applicability 3.0 Westinghouse STS 3.0-2 Rev. 5.0 If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

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 (exceptions to this Specification are stated in the individual Specifications); or TSTF-585, Rev. 4

HIS (Ice Condenser) 3.6.10 Westinghouse STS 3.6.10-1 Rev. 5.0 3.6 CONTAINMENT SYSTEMS 3.6.10 Hydrogen Ignition System (HIS) (Ice Condenser)

LCO 3.6.10 Two HIS trains shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One HIS train inoperable.

A.1 Restore HIS train to OPERABLE status.

OR A.2 Perform SR 3.6.10.1 on the OPERABLE train.

7 days

[OR In accordance with the Risk Informed Completion Time Program]

Once per 7 days B. One containment region with no OPERABLE hydrogen ignitor.

B.1 Restore one hydrogen ignitor in the affected containment region to OPERABLE status.

7 days

[OR In accordance with the Risk Informed Completion Time Program]

C. Both HIS trains inoperable.

OR More than one containment region with no OPERABLE hydrogen ignitor.

C.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months TSTF-585, Rev. 4

HIS (Ice Condenser) 3.6.10 Westinghouse STS 3.6.10-2 Rev. 5.0 CONDITION REQUIRED ACTION COMPLETION TIME OR Required Action and associated Completion Time not met.

TSTF-585, Rev. 4

MSIVs 3.7.2 Westinghouse STS 3.7.2-1 Rev. 5 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2

[Four] MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when all MSIVs are closed [and de-activated].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

[8] hours

[OR In accordance with the Risk Informed Completion Time Program]

B. More than one MSIV inoperable in MODE 1.

OR Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months C. ------------NOTE------------

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

[8] hours Once per 7 days D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months TSTF-585, Rev. 4

DC Sources - Operating 3.8.4 Westinghouse STS 3.8.4-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and Associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two DC electrical power subsystems inoperable.

E.1 Be in MODE 3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

TSTF-585, Rev. 4

Distribution Systems - Operating 3.8.9 Westinghouse STS 3.8.9-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC electrical power distribution subsystems inoperable.

C.1 Restore DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

E.1 Be in MODE 3.Enter LCO 3.0.3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Immediately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months TSTF-585, Rev. 4

LCO Applicability B 3.0 Westinghouse STS B 3.0-2 Rev. 5.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

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

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit; or b.c.. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

TSTF-585, Rev. 4

LCO Applicability B 3.0 Westinghouse STS B 3.0-3 Rev. 5.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit 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, a risk assessment addressing inoperable systems and components must be completed and appropriate risk management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk assessment must consider all inoperable equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures). The likely cause of the conditions that resulted in LCO 3.0.3 entry should be understood. A formal cause or apparent cause evaluation is not required because of the limited time available. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. Non-quantifiable factors should also be assessed. In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation. The impact on plant risk is evaluated from the baseline, zero-maintenance, condition.

TSTF-585, Rev. 4

LCO Applicability B 3.0 Westinghouse STS B 3.0-4 Rev. 5.0 Whenever practicable, a quantitative value for risk should be determined. If determination of a quantitative value for risk is not practicable, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continued operation for a limited time is acceptable.

If during the 24-hour period the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action must be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

Appropriate risk management actions are implemented in accordance with the Maintenance Rule procedures that are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

If the risk assessment determines that continuing operation is acceptable, that the appropriate risk management actions are implemented, and that entry into LCO 3.0.3 was unplanned, action to shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. It is not necessary for the planned restoration of compliance with the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are available, such as regulatory relief or an orderly shutdown. The 24-hour provision may not be used if the LCO 3.0.3 entry is planned, such as intentionally removing a train from service when the redundant train is inoperable. However, it may be used for emergent conditions that occur in parallel with other planned or unplanned inoperabilities.

The determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

If the risk assessment determines that continuing operation is not acceptable, if the risk assessment was not completed, the appropriate risk management actions were not implemented, or if entry into LCO 3.0.3 was planned, action to shut down the unit must be initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the risk assessment and implement risk management actions.

All times for completing actions and entering MODES are determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time TSTF-585, Rev. 4

LCO Applicability B 3.0 Westinghouse STS B 3.0-5 Rev. 5.0 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 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 unit, 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 times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit 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,

b.

The LCO is no longer applicable,

c.

A Condition exists for which the Required Actions have now been performed, or

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.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in MODE 5 when after a shutdown is initiated required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is requiredinitiated, the time limit for entering the next lower MODE applies.

If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a shutdown is initiated, then the time allowed for entering MODE 4 BASES LCO 3.0.3 (continued) is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 4 is not reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is initiated. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, 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 5 and 6 because the unit is already in the most TSTF-585, Rev. 4

LCO Applicability B 3.0 Westinghouse STS B 3.0-6 Rev. 5.0 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, 3, or 4) 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 unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.15, "Fuel Storage Pool Water Level." LCO 3.7.15 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.15 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.15 of "Suspend movement of irradiated fuel assemblies in the 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 unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not 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 following 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 ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in TSTF-585, Rev. 4

HIS (Ice Condenser)

B 3.6.10 Westinghouse STS B 3.6.10-4 Rev. 5.0 BASES ACTIONS (continued)

C.1 If both HIS trains are inoperable, if there is more than one containment region with no OPERABLE hydrogen ignitor, or if the HIS subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, tThe unit must be placed in a MODE in which the LCO does not apply if the HIS subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time.

This is done by placing the unit in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.10.1 REQUIREMENTS This SR confirms that [32] of 33 hydrogen ignitors can be successfully energized in each train. The ignitors are simple resistance elements.

Therefore, energizing provides assurance of OPERABILITY. The allowance of one inoperable hydrogen ignitor is acceptable because, although one inoperable hydrogen ignitor in a region would compromise redundancy in that region, the containment regions are interconnected so that ignition in one region would cause burning to progress to the others (i.e., there is overlap in each hydrogen ignitor's effectiveness between regions). [ The Frequency of 92 days has been shown to be acceptable through operating experience.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.6.10.2 This SR confirms that the two inoperable hydrogen ignitors allowed by SR 3.6.10.1 (i.e., one in each train) are not in the same containment region. [ The Frequency of 92 days is acceptable based on the Frequency of SR 3.6.10.1, which provides the information for performing this SR.

TSTF-585, Rev. 4

MSIVs B 3.7.2 Westinghouse STS B 3.7.2-3 Rev. 5.0 BASES LCO This LCO requires that [four] MSIVs in the steam lines be OPERABLE.

The MSIVs are considered OPERABLE when the isolation times are within limits, and they close on an isolation actuation signal.

This LCO provides assurance that the MSIVs will perform their design safety function to mitigate the consequences of accidents that could result in offsite exposures comparable to the 10 CFR 100 (Ref. 4) limits or the NRC staff approved licensing basis.

APPLICABILITY The MSIVs must be OPERABLE in MODE 1, and in MODES 2 and 3 except when closed and de-activated, when there is significant mass and energy in the RCS and steam generators. When the MSIVs are closed, they are already performing the safety function.

In MODE 4, normally most of the MSIVs are closed, and the steam generator energy is low.

In MODE 5 or 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the MSIVs are not required for isolation of potential high energy secondary system pipe breaks in these MODES.

ACTIONS A.1 With one MSIV inoperable in MODE 1, action must be taken to restore OPERABLE status within [8] hours [or in accordance with the Risk Informed Completion Time Program]. Some repairs to the MSIV can be made with the unit hot. The [8] hour Completion Time is reasonable, considering the low probability of an accident occurring during this time period that would require a closure of the MSIVs.

The [8] hour Completion Time is greater than that normally allowed for containment isolation valves because the MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment isolation valves in that the closed system provides an additional means for containment isolation.

B.1 If the MSIV cannot be restored to OPERABLE status within [8] hours, or if more than one MSIV is inoperable in MODE 1, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Condition C would be entered. The Completion Times are reasonable, based on operating experience, to reach MODE 2 and to close the MSIV(s) in an orderly manner and without challenging unit systems.

TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 Westinghouse STS B 3.8.4-8 Rev. 5.0 BASES ACTIONS (continued)

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

E.1 and E.2 If both DC electrical power subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 Westinghouse STS B 3.8.9-7 Rev. 5.0 BASES ACTIONS (continued)

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 and E.2 Condition E corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the [required] AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

OR TSTF-585, Rev. 4

LCO Applicability 3.0 Combustion Engineering STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 3 within 307 hours0.00355 days 0.0853 hours 5.076058e-4 weeks 1.168135e-4 months ,

b.

[MODE 4 within 3613] hours, and

c.

MODE 5 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b.

MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

TSTF-585, Rev. 4

LCO Applicability 3.0 Combustion Engineering STS 3.0-2 Rev. 5.0 If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

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 (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.

TSTF-585, Rev. 4

MSIVs 3.7.2 Combustion Engineering STS 3.7.2-1 Rev. 5.0 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2

[Two] MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when all MSIVs are closed [and de-activated].

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

[8] hours

[OR In accordance with the Risk Informed Completion Time Program]

B. More than one MSIV inoperable in MODE 1.

OR Required Action and Associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months C. ------------NOTE------------

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

[8] hours Once per 7 days D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months TSTF-585, Rev. 4

DC Sources - Operating 3.8.4 Combustion Engineering STS 3.8.4-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and Associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two DC electrical power subsystems inoperable.

E.1 Be in MODE 3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

TSTF-585, Rev. 4

Distribution Systems - Operating 3.8.9 Combustion Engineering STS 3.8.9-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC electrical power distribution subsystems inoperable.

C.1 Restore DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours E. Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

E.1 Be in MODE 3.Enter LCO 3.0.3.

AND E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Immediately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to

[required] AC, DC, and AC vital bus electrical power distribution subsystems.

[ 7 days OR In accordance with the Surveillance Frequency Control Program ]

TSTF-585, Rev. 4

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-2 Rev. 5.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:

a.

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

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit; or

c.

. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

TSTF-585, Rev. 4

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-3 Rev. 5.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit 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, a risk assessment addressing inoperable systems and components must be completed and appropriate risk management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk assessment must consider all inoperable equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures). The likely cause of the conditions that resulted in LCO 3.0.3 entry should be understood. A formal cause or apparent cause evaluation is not required because of the limited time available. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. Non-quantifiable factors should also be assessed. In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation. The impact on plant risk is evaluated from the baseline, zero-maintenance, condition.

TSTF-585, Rev. 4

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-4 Rev. 5.0 Whenever practicable, a quantitative value for risk should be determined. If determination of a quantitative value for risk is not practicable, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continued operation for a limited time is acceptable.

If during the 24-hour period the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action must be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

Appropriate risk management actions are implemented in accordance with the Maintenance Rule procedures that are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

If the risk assessment determines that continuing operation is acceptable, that the appropriate risk management actions are implemented, and that entry into LCO 3.0.3 was unplanned, action to shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. It is not necessary for the planned restoration of compliance with the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are available, such as regulatory relief or an orderly shutdown. The 24-hour provision may not be used if the LCO 3.0.3 entry is planned, such as intentionally removing a train from service when the redundant train is inoperable. However, it may be used for emergent conditions that occur in parallel with other planned or unplanned inoperabilities.

The determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

If the risk assessment determines that continuing operation is not acceptable, if the risk assessment was not completed, the appropriate risk management actions were not implemented, or if entry into LCO 3.0.3 was planned, action to shut down the unit must be initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the risk assessment and implement risk management actions.

All times for completing actions and entering MODES are determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time TSTF-585, Rev. 4

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-5 Rev. 5.0 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 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 unit, 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 times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit 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,

b.

The LCO is no longer applicable,

c.

A Condition exists for which the Required Actions have now been performed, or

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.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in MODE 5 when after a shutdown is required initiated during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is requiredinitiated, the time limit for entering the next lower MODE applies.

If a lower MODE is entered in less time than allowed, however, the total allowable time to enter BASES LCO 3.0.3 (continued)

MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a shutdown is initiated, then the time allowed for entering MODE 4 is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 4 is not reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is initiated. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, 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 5 and 6 because the unit is already in the most TSTF-585, Rev. 4

LCO Applicability B 3.0 Combustion Engineering STS B 3.0-6 Rev. 5.0 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, 3, or 4) 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 unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.16, "Fuel Storage Pool Water Level." LCO 3.7.16 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.16 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.16 of "Suspend movement of irradiated fuel assemblies in 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.

[ The requirement to be in MODE 4 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months is plant specific and depends on the ability to cool the pressurizer and degas. ]

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 unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

TSTF-585, Rev. 4

MSIVs B 3.7.2 Combustion Engineering STS B 3.7.2-4 Rev. 5.0 BASES ACTIONS A.1 With one MSIV inoperable in MODE 1, time is allowed to restore the component to OPERABLE status. Some repairs can be made to the MSIV with the unit hot. The [8] hour Completion Time is reasonable, considering the probability of an accident occurring during the time period that would require closure of the MSIVs. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

The [8] hour Completion Time is greater than that normally allowed for containment isolation valves because the MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment isolation valves in that the closed system provides an additional means for containment isolation.

B.1 If the MSIV cannot be restored to OPERABLE status within [8] hours, or if more than one MSIV is inoperable in MODE 1, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Condition C would be entered. The Completion Time is reasonable, based on operating experience, to reach MODE 2, and close the MSIV(s) in an orderly manner and without challenging unit systems.

C.1, C.2.1, and C.2.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

The [8] hour Completion Time is consistent with that allowed in Condition A.

Inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 Combustion Engineering STS B 3.8.4-9 Rev. 5.0 BASES ACTIONS (continued)

The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

E.1 and E.2 If both DC electrical power subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer ([2.20] Vpc times the number of connected cells or [127.6] V for a 58 cell battery at the battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life. [ The 7 day Frequency is consistent with manufacturer recommendations.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 Combustion Engineering STS B 3.8.9-7 Rev. 5.0 BASES ACTIONS (continued)

E.1 and E.2 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES

1.

FSAR, Chapter [6].

2.

FSAR, Chapter [15].

3.

Regulatory Guide 1.93, December 1974.

TSTF-585, Rev. 4

LCO Applicability 3.0 General Electric BWR/4 STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement required appropriate management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 2 within [30 7] hours,

b.

MODE 3 within 3613 hours0.0418 days 1.004 hours 0.00597 weeks 0.00137 months , and

c.

MODE 4 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 2 within [12] hours,

b.

MODE 3 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 4 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

TSTF-585, Rev. 4

LCO Applicability 3.0 General Electric BWR/4 STS 3.0-2 Rev. 5.0 If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

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

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 712 hours0.00824 days 0.198 hours 0.00118 weeks 2.70916e-4 months to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; TSTF-585, Rev. 4

DC Sources - Operating 3.8.4 General Electric BWR/4 STS 3.8.4-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore DC electrical power subsystem to OPERABLE status.

[2] hours

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and Associated Completion Time of Condition A[, B, or C] not met for station service DC subsystem.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. Two station service DC subsystems inoperable.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FE. [ Required Action and associated Completion Time of Condition A[, B, or C] not met for DG DC subsystem.

FE.1 Declare associated DG inoperable.

Immediately ]

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

[ 7 days OR In accordance with the TSTF-585, Rev. 4

Distribution Systems - Operating 3.8.9 General Electric BWR/4 STS 3.8.9-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more [station service] DC electrical power distribution subsystems inoperable.

C.1 Restore DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. [ One or more DG DC electrical power distribution subsystems inoperable.

E.1 Declare associated DG(s) inoperable.

Immediately ]

F. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

F.1 Be in MODE 3.Enter LCO 3.0.3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-2 Rev. 5.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.10, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

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

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit; or

c.

. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-3 Rev. 5.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit 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, a risk assessment addressing inoperable systems and components must be completed and appropriate risk management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk assessment must consider all inoperable equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures). The likely cause of the conditions that resulted in LCO 3.0.3 entry should be understood. A formal cause or apparent cause evaluation is not required because of the limited time available. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. Non-quantifiable factors should also be assessed. In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation. The impact on plant risk is evaluated from the baseline, zero-maintenance, condition.

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-4 Rev. 5.0 Whenever practicable, a quantitative value for risk should be determined. If determination of a quantitative value for risk is not practicable, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continued operation for a limited time is acceptable.

If during the 24-hour period the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action must be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

Appropriate risk management actions are implemented in accordance with the Maintenance Rule procedures that are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

If the risk assessment determines that continuing operation is acceptable, that the appropriate risk management actions are implemented, and that entry into LCO 3.0.3 was unplanned, action to shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. It is not necessary for the planned restoration of compliance with the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are available, such as regulatory relief or an orderly shutdown. The 24-hour provision may not be used if the LCO 3.0.3 entry is planned, such as intentionally removing a train from service when the redundant train is inoperable. However, it may be used for emergent conditions that occur in parallel with other planned or unplanned inoperabilities.

The determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

If the risk assessment determines that continuing operation is not acceptable, if the risk assessment was not completed, the appropriate risk management actions were not implemented, or if entry into LCO 3.0.3 was planned, action to shut down the unit must be initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the risk assessment and implement risk management actions.

All times for completing actions and entering MODES are determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation.

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-5 Rev. 5.0 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 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 unit, 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 times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit 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,

b.

The LCO is no longer applicable,

c.

A Condition exists for which the Required Actions have now been performed, or

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.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in MODE 4 when after a shutdown is initiated required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is initiated required, the time limit for entering the next lower MODE applies. If a lower MODE is entered in BASES LCO 3.0.3 (continued) less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a shutdown is initiated, then the time allowed for entering MODE 3 is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 3 is not reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is initiated. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to 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 TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-6 Rev. 5.0 apply in MODES 4 and 5 because the unit 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 unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.8, "Spent Fuel Storage Pool Water Level." LCO 3.7.8 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 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of "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 unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not 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 following 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 ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 General Electric BWR/4 STS B 3.8.4-8 Rev. 5.0 BASES ACTIONS (continued)

2.

[LICENSEE] will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 2, "Technical Specifications End States, NEDC-32988-A," November 2009.

If the inoperable station service DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimized.

To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 and E.2 If both station service DC subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 General Electric BWR/4 STS B 3.8.4-9 Rev. 5.0 FE.1 If the DG DC electrical power subsystem cannot be restored to OPERABLE status in the associated Completion Time, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable. This declaration also requires entry into applicable Conditions and Required Actions for an inoperable DG, LCO 3.8.1, "AC Sources - Operating."

TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 General Electric BWR/4 STS B 3.8.9-7 Rev. 5.0 BASES ACTIONS (continued)

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

[ E.1 With one or more DG DC buses inoperable, the associated DG(s) may be incapable of performing their intended functions. In this situation the DG(s) must be immediately declared inoperable. This action also requires entry into applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating." ]

F.1 and F.2 Condition F corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

TSTF-585, Rev. 4

LCO Applicability 3.0 General Electric BWR/6 STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

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

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems and components and implement appropriate risk management actions. If the risk assessment determines that continuing operation is acceptable, the appropriate risk management actions are implemented, and entry into LCO 3.0.3 was unplanned, then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a.

MODE 2 within 307 hours0.00355 days 0.0853 hours 5.076058e-4 weeks 1.168135e-4 months ,

b.

MODE 3 within 3613 hours0.0418 days 1.004 hours 0.00597 weeks 0.00137 months , and

c.

MODE 4 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed, the appropriate risk management actions were not implemented, or entry into LCO 3.0.3 was planned, then action shall be initiated to place the unit, as applicable, in:

a.

MODE 2 within [12] hours,

b.

MODE 3 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c.

MODE 4 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

TSTF-585, Rev. 4

LCO Applicability 3.0 General Electric BWR/6 STS 3.0-2 Rev. 5.0 If Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, then completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

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 (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.

TSTF-585, Rev. 4

DC Sources - Operating 3.8.4 General Electric BWR/6 STS 3.8.4-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. [Division 1 or 2] DC electrical power subsystem inoperable for reasons other than Condition A [or B].

C.1 Restore [Division 1 and 2]

DC electrical power subsystems to OPERABLE status.

[2] hours

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time for [Division 1 or 2]

DC electrical power subsystem for Condition A, B, or C not met.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. [Division 1 and 2] DC electrical power subsystems inoperable.

E.1 Be in MODE 3.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours FE. [Division 3] DC electrical power subsystem inoperable for reasons other than Condition A

[or B].

FE.1 Declare High Pressure Core Spray System

[and 2C Standby Service Water System] inoperable.

Immediately GF. Required Action and associated Completion Time for [Division 3] DC electrical power subsystem for Condition A, B, or FE not met.

GF.1 Be in MODE 3.

AND GF.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours TSTF-585, Rev. 4

Distribution Systems - Operating 3.8.9 General Electric BWR/6 STS 3.8.9-2 Rev. 5.0 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more [Division 1 and 2] DC electrical power distribution subsystems inoperable.

C.1 Restore [Division 1 and 2]

DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR In accordance with the Risk Informed Completion Time Program]

D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

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

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. One or more [Division 3]

AC, DC, or AC vital bus electrical power distribution subsystems inoperable.

E.1 Declare High Pressure Core Spray System [and 2C Standby Service Water System] inoperable.

Immediately F. Two or more electrical power distribution subsystems inoperable that result in a loss of function.

F.1 Be in MODE 3.Enter LCO 3.0.3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-2 Rev. 5.0 BASES LCO 3.0.2 (continued)

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.11, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The ACTIONS for not meeting a single LCO adequately manage any increase in plant risk, provided any unusual external conditions (e.g., severe weather, offsite power instability) are considered. In addition, the increased risk associated with simultaneous removal of multiple structures, systems, trains or components from service is assessed and managed in accordance with 10 CFR 50.65(a)(4). Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

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

b.

The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit; or

c.

. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-3 Rev. 5.0 BASES LCO 3.0.3 (continued)

This Specification delineates the time limits for placing the unit 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, a risk assessment addressing inoperable systems and components must be completed and appropriate risk management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk assessment must consider all inoperable equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures). The likely cause of the conditions that resulted in LCO 3.0.3 entry should be understood. A formal cause or apparent cause evaluation is not required because of the limited time available. If the extent of condition is unknown, the risk assessment should consider the possibility of common cause failure either numerically or through risk management actions.

Continuing operation for a limited time is acceptable if the risk assessment determines that for the current plant configuration, the Incremental Core Damage Probability (ICDP) is less than 1E-5, and the Incremental Large Early Release Probability (ILERP) is less than 1E-6. Non-quantifiable factors should also be assessed. In addition, the configuration-specific Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) should be evaluated to identify high-risk situations. A configuration-specific CDF in excess of 1E-3/year or LERF in excess of 1E-4/year does not support continuing operation. The impact on plant risk is evaluated from the baseline, zero-maintenance, condition.

TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-4 Rev. 5.0 Whenever practicable, a quantitative value for risk should be determined. If determination of a quantitative value for risk is not practicable, a qualitative assessment of risk may be used with appropriate consideration of the plant conditions and uncertainties to determine whether continued operation for a limited time is acceptable.

If during the 24-hour period the plant configuration changes such that plant risk may be increased, the risk must be reassessed. If the configuration no longer supports continuing plant operation, action must be initiated to shut down the unit in accordance with the LCO 3.0.3 requirements.

Appropriate risk management actions are implemented in accordance with the Maintenance Rule procedures that are appropriate for the current plant condition and the inoperable equipment. Risk management actions are used to address non-quantifiable factors, increase risk awareness, and reduce the risk magnitude and duration.

If the risk assessment determines that continuing operation is acceptable, that the appropriate risk management actions are implemented, and that entry into LCO 3.0.3 was unplanned, action to shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3. It is not necessary for the planned restoration of compliance with the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are available, such as regulatory relief or an orderly shutdown. The 24-hour provision may not be used if the LCO 3.0.3 entry is planned, such as intentionally removing a train from service when the redundant train is inoperable. However, it may be used for emergent conditions that occur in parallel with other planned or unplanned inoperabilities.

The determination that continuing operation is acceptable should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

If the risk assessment determines that continuing operation is not acceptable, if the risk assessment was not completed, the appropriate risk management actions were not implemented, or if entry into LCO 3.0.3 was planned, action to shut down the unit must be initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the risk assessment and implement risk management actions.

All times for completing actions and entering MODES are determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-5 Rev. 5.0 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 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 unit, 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 times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit 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,

b.

The LCO is no longer applicable,

c.

A Condition exists for which the Required Actions have now been performed, or

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.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in MODE 4 when after a shutdown is initiated required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is requiredinitiated, the time limit for entering the next lower MODE applies.

If a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if BASES LCO 3.0.3 (continued)

MODE 2 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a shutdown is initiated, then the time allowed for entering MODE 3 is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 3 is not reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is initiated. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to 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 TSTF-585, Rev. 4

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-6 Rev. 5.0 apply in MODES 4 and 5 because the unit 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 unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, "Fuel Pool Water Level." LCO 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the associated 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 unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" 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 unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not 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 following 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 ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 General Electric BWR/6 STS B 3.8.4-8 Rev. 5.0 BASES ACTIONS (continued)

2.

[LICENSEE] will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 2, "Technical Specifications End States, NEDC-32988-A," November 2009.

If a Division 1 or 2 DC electrical power subsystem is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 and E.2 If both [Division 1 and 2] DC electrical power subsystems are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

TSTF-585, Rev. 4

DC Sources - Operating B 3.8.4 General Electric BWR/6 STS B 3.8.4-9 Rev. 5.0 BASES ACTIONS (continued)

FE.1 With the Division 3 DC electrical power subsystem inoperable for reasons other than Condition A or B, the HPCS and 2C Standby Service Water System may be incapable of performing their intended functions and must be immediately declared inoperable. This declaration also requires entry into applicable Conditions and Required Actions of LCO 3.5.1, "ECCS -

Operating," [and LCO 3.7.1, "Standby Service Water (SSW)] System and

[Ultimate Heat Sink (UHS)")).

GF.1 and GF.2 If the inoperable Division 3 DC electrical power subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer ([2.20] Vpc times the number of connected cells or [127.6] V for a 58 cell battery at the battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life. [ The 7 day Frequency is consistent with manufacturer recommendations.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 General Electric BWR/6 STS B 3.8.9-7 Rev. 5.0 BASES ACTIONS (continued)

If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, the plant must be bought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, 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.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With the Division 3 electrical power distribution system inoperable, the Division 3 powered systems are not capable of performing their intended functions. Immediately declaring the high pressure core spray inoperable allows the ACTIONS of LCO 3.5.1, "ECCS - Operating," to apply appropriate limitations on continued reactor operation.

F.1 and F.2 Condition F corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.

(Single division systems are not included, although for this Action, Division 3 is considered redundant to Division 1 and 2 ECCS.) When two or more inoperable electrical power distribution subsystems result in the TSTF-585, Rev. 4

Distribution Systems - Operating B 3.8.9 General Electric BWR/6 STS B 3.8.9-8 Rev. 5.0 BASES ACTIONS (continued) loss of a required function, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS Meeting this Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. [ The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES

1.

FSAR, Chapter [6].

2.

FSAR, Chapter [15].

3.

Regulatory Guide 1.93, December 1974.

4.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

TSTF-585, Rev. 4

v t e Letter Sequence Request
EPID:L-2023-PMP-0000, TSTF-585 (Open)
Initiation Request, Request Acceptance, Acceptance Administration Meeting, Meeting Questions Answers Results Approval... Other: ML24302A210, ML24318B831, ML25219A024
MONTHYEAR2024-11-13 [Table View]

ML25066A098

Text

SUBJECT:

Description:

Description:

Description:

Description:

Description:

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Description:

SUMMARY

SUMMARY

SUBJECT:

Enclosure:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

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