NG-15-0230, License Amendment Request (TSCR-1 54) to Correct Examples in Technical Specifications Section 1.4, Frequency.

License Amendment Request (TSCR-1 54) to Correct Examples in Technical Specifications Section 1.4, Frequency.

ML15246A408
Person / Time
Site:	Duane Arnold
Issue date:	07/24/2015
From:	Vehec T NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-15-0230
Download: ML15246A408 (16)

Text

- _ .~.----N E-x era ENERG",Y'_ -

10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 License Amendment Request (TSCR-1 54) to Correct Examples in Technical Specifications Section 1.4, "Freqiuency"

References:

1. Letter, M. Peifer (Nuclear Management Company, LLC) to USNRC, "Technical Specification Change Request (TSCR-029): 'Adoption of NRC Approved Generic Changes to Improved Technical Specifications' Affected Technical Specifications: Sections 1.4, 3.3.1.1, 5.5.2, 5.5.11," NG-04-0037, dated January 28, 2004 (ML040410564)

2. Letter, D. Spaulding (USNRC) to M. Peifer (Nuclear Management.Company, LLC), Duane Arnold Energy Center - Issuance of Amendment to ReVise the Technical Specifications by Adopting TSTF Nos. 273, 284, and 299 (TAC NO.

MC2023), May 12, 2005 (ML05111i0692)

In accordance with the provisions of Section 50..90 of Title 10 of the Code of Federal Regulations (10 CFR), NeXtEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) is submitting a request for an amendment to the Technical Specifications (TS) for Duane Arnold Energy Center (DAEC).

The proposed amendment consiSts of editorial corrections to TS .Section 1.4, "Frequency." Example 1.4-1 would be revised to be consistent with NRC-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-485, Revision 0, "Correct Example 1.4-1." Example 1.4-5 and Example 1.4-6 would be revised to reflect the changes requested by Reference 1 and issued with typographical errors in Reference 2.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA52324 * ~ ,tet0 OP CO(_

c,,-, qc 2l~s

Document- Control Desk -.......... ..

NG-l 5-0230 Page 2 of 2 Attachment I provides an evaluation of the proposed changes. Attachment 2 provides marked-up pages of existing TS to show the proposed changes. Attachment 3 provides revised (clean) TS pages. There are no new Regulatory Commitments or revisions to existing Regulatory Commitments.

Although this request is neither"outage related nor required by any specific date, NextEra Energy Duane Arnold requests a prompt review of the proposed license amendment, with the amendment being .implemented within 60 days of its receipt.

In accordance with 10 CFR 50.91 (a)(1), "Notice for Public Comment," the analysis about the iSSUe of no significant hazards consideration using the standards in 10 CFR 50..92 is being provided to the Commission.

In accordance with 10 CFR 50.91(b)(1), "Notice for Public Comment; State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated State of Iowa official.

The DAEC Onsite Review Group has reviewed the proposed license amendment request.

If you have any questions or require additional information, please contact J. Michael Davis at 319-851-*7032.

I declare under penalty of perjury that the foregoing is true and correct.

Executed oni July 24, 2015.

T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Attachments: As stated cc: Regional Administrator, USNRC, Region Ill, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

ATTACHMENT I to NG-15-0230 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-1 54)

TO CORRECT EXAMPLES IN TECHNICAL SPECIFICATIONS SECTION 1.4, "FREQUENCY" EVALUATION OF PROPOSED CHANGES*

2.0 PROPOSED CHANGE

S 3.0 HISTORY

5.0 TECHNICAL ANALYSIS

6.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

7.0 ENVIRONMENTAL CONSIDERATION

8.0 PRECEDENT

9.0 REFERENCES

5 pages follow

1.0 DESCRIPTION

The requested amendment consists of editorial corrections to Technical Specifications (TS)

Section 1.4, "Frequency." Example 1.4-1 would be revised to be consistent with NRC-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-485, Revision 0, "Correct Example 1.4-1 ." Example 1.4-5 and Example 1.4-6 would be revised to correct typographical errors.

2.0 PROPOSED CHANGE

S The proposed changes make the following corrections:

SExample 1.4-1 would be revised to be consistent with the requirements of Surveillance Requirement (SR) 3.0.4. The second paragraph states:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4.

The second paragraph would be revised to read:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

• Example 1.4-5 would be revised to correct the Note.

The Note states:

Only required to be met in MODE 1.

The Note would be revised to read:

Only required to be performed in MODE 1.

• Example 1.4-6 would be revised to correct the Note.

The Note states:

Not required to be in MODE 3.

The Note would be revised to read:

Not required to be met in MODE 3.

Page 1 of 5

A marked-up copy of the proposed changes to TS Section 1.4 is provided in Attachment 2.

There are no TS Bases changes associated with this license amendment request.

3.0 HISTORY TSTF-485, Revision 0 identifies a correction to TS Section 1.4, Example 1.4-1Ito be consistent with the requirements of SR 3.0.4 previously changed by TSTF-359, Revision 9. Duane Arnold Energy Center (DAEC) adopted TSTF-359 via. Reference 9.1. Therefore, the correction identified in TSTF-485, Revision 0, which was approved by the NRC via Reference 9.2 is applicable to DAEC.

Technical Specification Change Request (TSCR-029), which in part requested adoption of TSTF-284, Revision 3 regarding the addition of discussion paragraphs and examples to facilitate the use and application of SR Notes that utilize 'met" and "perform,"' was submitted for DAEC by Reference 9.3. Reference 9.4 issued Amendment 258 to the DAEC Operating License. The Safety Evaluation associated with Amendment 258 regarding TSTF-284, Revision 3 proposed changes states in part:

o Add Examples 1.4-5 and 1.4-6, which explain the use of the following two SR notes, respectively: 'Only required to be performed in MODE 1," and "Not required to be met in MODE 3." [Section 3.3.1.a]

• The additional discussion and examples provided by TSTF 284, described previously in 3.3.1.a, are acceptable because they extend the guidance, which explains the proper meaning and use of SR notes that modify surveillance applicability and frequency requirements, so that it is comprehensive, and consistent among the 5 STS NUREGs.

Application of TSTF 284 to the DAEC TSs clarifies the existing guidance, but has no adverse effect on safety because it does not reduce any operational restrictions or testing requirements. Therefore, adoption of TSTF 284, Rev 3 is acceptable. [Section 3.2.2]

The Technical Specification pages issued by Amendment 258 provided:

• New Example 1.4-5 with a Note that stated, "Only required to be met in MODE 1."

• New Example 1.4-6 with a Note that stated, "Not required to be in MODE 3."

4.0 BACKGROUND

TSTF-359, Revision 9 "Increase Flexibility in MODE Restraints," revised LCO 3.0.4 and SR 3.0.4. The changes made in TSTF-359 to SR 3.0.4 have made certain statements in Example 1.4-1 incorrect.

5.0 TECHNICAL ANALYSIS

The proposed changes are editorial in nature and do not require a technical analysis.

6.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION NextEra Energy Duane Arnold, LLC (NextEra Energy Duane Arnold) has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

Page 2 of.5

Description of Amendment Request: The proposed changes consist of editorial corrections to TS Section 1.4, "Frequency."

Basis for proposed no significant hazards determination: As required by 10 CFR 50.91(a), the NextEra Energy Duane Arnold analysis of the issue of no significant hazards consideration is presented below:

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

Response: No The proposed changes are editorial in nature and have no effect on accident scenarios previously evaluated. The proposed changes consist of editorial corrections to TS Section 1.4, "Frequency," that would make the Duane Arnold Energy Center (DAEC) TS consistent with the Standard Technical Specifications for General Electric BWR/4 Plants (NUREG-1433). The proposed changes do not affect initiating events for accidents previously evaluated and do not affect or modify plant systems or procedures used to mitigate the progression or outcome of those accident scenarios.

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

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

Response: No The proposed changes are editorial in nature consisting of editorial corrections to TS Section 1.4, 'Frequency." The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. No new accident sceharios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes.

The proposed changes do not introduce any new accident precursors, nor do they impose any new or different requirements or eliminate any existing requirements. The proposed changes do not alter assumptions made in the safety analysis.

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

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

Response: No Margin of safety is related to confidence in the ability of the fission product barriers (fuel cladding, reactor coolant system, and primary containment) to perform their design functions during and following postulated accidents. The proposed changes are editorial in nature consisting of editorial corrections to TS Section 1 .4, "Frequency." No Setpoints Page 3 of 5

at which protective actions are initiated are altered by the proposed changes. The proposed changes do. not alter the manner in which the safety limits are determined.

These changes are consistent with plant design and do not change th~e TS operability requirements; thus, previously evaluated accidents are not affected by this proposed change.

Therefore, the proposed Changes do not involve a significant reduction in a margin of safety.

7.0 ENVIRONMENTAL CONSIDERATION

10 CFR 51.22(c)(10) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment of an operating license for a facilitY requires no environmental assessment, ifthe proposed amendment: (1) changes surety, insurance and/or indemnity requirements, (2) changes rec(*rdkeeping, reporting, or administrative procedures or requirements, (3) changes the licensee's or~permit holder's name, phone number, business or~e-mail address, (4) changes the name, position, or title of an officer of the licensee or permit holder, including but not limited to the radiation safety officer or quality assurance manager, or (5) changes the format of the license or permit br otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. NextEra Energy Duane Arnold has reviewed this license amendmenit request an~d determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51..22(c)(1O). Pursuant to 10 CFR 51.22(b), no*

environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination is as follows.

Basis:

The proposed amendment consists of editorial corrections to TS Section 1.4, 'Frequency."

Accordingly, the changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10)(V). Therefore, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

8.0 PRECEDENT This License Amendment Request is similar to a License Amendment Request approved by letter dated August.16, 2007 (ML071990307), "Indian Point Nuclear Generating Unit Nos. 2 and 3 - Issuance of Amendments RE: Proposed Changes to Technical Specifications:

Miscellaneous Editorial Changes, Including TSTF-485 (TAC NOS. MD3074 and MD3075),"

which is Reference 9.5.

9,0 REFERENCES 9.1 Letter, 0. Beaulieu (USNRC) to M. Peifei" (Nuclear Management Company, LLC), Duane Arnold Energy Center - Issuance of Amendment to Re: Increased Flexibility in MODE Restraints (TAC NO. MC1711), January 10, .2005 (ML043450083)*

9.2 Letter, T. Boyce (USNRC) to Technical Specifications Task Force, Status of TSTF 343, 479, 482, 485, December 6, 2005 (ML053460302)

Page 4 of 5

9.3 Letter, M. Peifer (Nuclear Management Company, LLC) oftoNRC USNRC, "Technical Specification Change Request (TSCR-029): 'Adoption Approved Generic Changes to Improved Technical Specifications' Affected Technical Specifications:

Sections 1.4, 3.3.1t.1, 5.5.2, 5.5.11 ," NG-04-0037, dated January 28, 2004 (ML040410564) 9.4 Letter, 0. Spaulding (USNRC) to M. Peifer (Nuclear Management Company, LLC), Duane Arnold Energy Center - Issuance of Amendment to Revise the Technical Specifications by Adopting TSTF Nos. 273, 284, and 299 (TAG NO. MC2023), May 12, 2005 (ML051 11069.2) 9.5 Letter, J. Boska (USNRC) to M. Balduzzi (Entergy Nuclear Operations, Inc,), Indian Point Nuclear Generating Unit Nos. 2 and 3 - Issuance of Amendments RE: Proposed Changes to Technical Specifications: Miscellaneous Editorial Changes, Including TSTF-485 (TAC NOS. MD3074 and MD3075), August 16, 2007 (ML071990307)

Page 5 of 5

ATTACHMENT 2 to NG-t5-0230 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-1 54)

TO CORRECT EXAMPLES IN TECHNICAL SPECIFICATIONS SECTION 1.4, "FREQUENCY" PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKUP COPY) 3 pages follow

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that

• Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS _______

SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-I contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.9.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable..

Ithen SR 3.0.4 becomes applicable. T, Ii.# moifiei 'If the interval as specified by SR 3.0.2 is exceede while the unit

,.a mdifedby SR 3.0.3, isnt in a MODE or other specified condition in the .Applicabifityof

.... he rhWhich performance of the SR is required, The

.Surveillance m eformed within the Frequency requirements of SR 3.0.2 prior to entiy into the MODE or other specified condition. Failure to- do... woul .... ti a*";ol'-o" o-SR-3.0.4

]or the LCO is:considered not met (in accordance' Iwith SR 3.0.1:) an~d ,LCO, 3.0.4-bec0,re~sap~plicable.

(continued)

DAEC i .4-3 DAEC 1.4-3Amendment No.

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-5 (continued)

SURVEILLANCE REQUIREMENTS______

SURVEILLANCE FREQUENCY

.................--- ... NO TE-...... ... .......... ...

Only required to b e__.et in MODE 1.

pfomd Perform comPlete cycle of the valve 7 days The interval continues, whether or not the unit operation is in MODE 1, 2 or 3 (the assumed Applicability of the associated LCO) between performances.

As the Note modifies the required performance of the Surveillance, the Note is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is not in MODE 1, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency" if completed prior to entering MODE 1.

Therefore, ifthe Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was not in MODE 1, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.'0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not result in entry into MODE 1.

Once the unit reaches MODE 1, the requirement for the Surveillance to be performed within its specified Frequency applies and would require that the Surveillance had been performed. If the Surveillance were not performed prior to entering MODE 1, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

(continued)

DAEC 1.4-7 DAE 1.-7Amendment No. 2.,58

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-6 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

.... ... .... ... .... ... N OTE-.--... ... ... .... ... ...

Not required to bei MODE 3.

Verify parameter is within limits. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1.4-6 specifies that the requirements of this Surveillance do not have to be met while the unit is in MODE 3 (the assumed Applicability of the associated LCO is MODES 1, 2, and 3). The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-I. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the SUrveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), and the unit was in MODE 3, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES to enter MODE 3, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded, provided the MODE change does not result in entry into MODE 2. Prior to entering MODE 2 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met), SR 3.0.4 would require satisfying the SR.

DAEC 1.4-8 DAEC .4-8Amendment No. 2578

ATTACHMENT 3 to NG-15-0230 NEXTESRA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-1 54)

TO CORRECT EXAMPLES IN TECHNICAL SPECIFICATIONS SECTION 1.4, "FREQUENCY"

• REVISED TECHNICAL SPECIFICATION PAGES 3 pages follow

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS _______

SURVEILLANCE FREQUENCY-Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example the 1.4-1Specifications Technical contains the type (TS).of The SR most often encountered Frequency specifies an in interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable.

If the intervalas specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

(continued)

DAEC 1.4-3 DAEC .4-3Amendment No.

... ........ .......... ... .......F req u e n cy ..

1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-5

.(continued)

SURVEILLANCE REQUIREMENTS______

SURVEILLANCE FREQUENCY

--- ..----------------... NOTE--------

Only required to be performed in MODE 1.

Perform complete cycle of the valve 7 days The interval continues, whether or not the unit operation is in MODE 1, 2 or 3 (the assumed Applicability of the associated LCO) between performances.

As the Note modifies the required performance of the Surveillance, the Note is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is not in MODE 1, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency" if completed prior to entering. MODE 1.

Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was not in MODE 1, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not result in entry into MODE 1.

Once the unit reaches MODE. 1, the requirement for the Surveillance to be performed within, its specified Frequency applies and would require that the Surveillance had been performed.. If the Surveillance were not performed prior to entering MODE 1, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

(continued)

DAEC 1.4-7 DAEC .4-7Amendment No.

__ _ _* -........... -Frequency1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-6 (continued)

SURVEILLANCE. REQUIREMENTS SURVEILLANCE FREQUENCY

..................---- NOTE-..........--- ..........

Not required to be met in MODE 3.

Verify parameter is within limits.. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Example 1i-.4-6 specifies that the requirements of this Surveillance do not have to-be met while-the unit is in MODE 3 (the assumed Applicability of the associated LCO is MODES 1, 2, and 3). The interval measurement for the Frequency of this Surveillance continues at all times, as describ~ed in Example 1.4-i1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance. Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), and the unit Wgas in MODE 3, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES to enter MODE 3, even with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency exceeded:, provided the MODE change does not result in entry into MODE 2. Prior to entering MODE 2 (assuming again that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency were not met), SR 3.0.4 would require satisfying the SR.

DAEC 1.4-8 DAEC .4-8Amendment No.