Text

Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules
	ML17199F771
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Robinson, McGuire
Issue date:	07/18/2017
From:	Henderson K; Duke Energy Carolinas, Duke Energy Corp, Duke Energy Progress, Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-17-0001
	Download: ML17199F771 (71)
	v • d • e

(~ DUKE KELVIN HENDERSON Senior Vice President ENERGY. Nuclear Corporate 526 S. Church Street, EC-07H Charlotte, NC 28202 980-373-1295 KeMn.Hendersol@duke-energy.com 10 CFR 50.90 Serial: RA-17-0001 July 18, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 CATAWBA NUCLEAR STATION, UNITS 1AND2 DOCKET NOS. 50-413 AND 50-414 /RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNITS 1AND2 DOCKET NOS. 50-369 AND 50-370 I RENEWED LICENSE NOS. NPF-9 AND NPF-17 OCONEE NUCLEAR STATION, UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-269, 50-270 AND 50-287 /RENEWED LICENSE NOS. DPR-38, DPR-47 AND DPR-55 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 I RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23

SUBJECT:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-529, "CLARIFY USE AND APPLICATION RULES" Pursuant to 10 CFR 50.90, Duke Energy Progress, LLC, and Duke Energy Carolinas, LLC, collectively referred to henceforth as "Duke Energy, " is submitting a request for amendments to the Technical Specifications (TS) for Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS) , Units 1 and 2; Oconee Nuclear Station (ONS), Units 1, 2 and 3; Shearon Harris Nuclear Power Plant (HNP), Unit 1; and H. B. Robinson Steam Electric Plant (RNP), Unit No. 2.

The proposed amendments would modify TS requirements in Section 1.3 and Section 3.0 (4.0.3 for HNP) regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4 .

Attachment 1 provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides existing TS Bases pages marked up to show the proposed change. Changes to the existing TS Bases will be implemented under the Technical Specification Bases Control

U.S. Nuclear Regulatory Commission RA-17-0001 Page2 Program. They are provided in Attachment 3 for information only. The retyped TS pages will be provided to the NRC immediately prior to issuance of the approved amendments.

The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the proposed change involves no significant hazards consideration. The bases for these determinations are included in .

This submittal contains no regulatory commitments.

Duke Energy requests approval of the proposed change by July 18, 2018. Once approved , the amendments will be implemented within 120 days.

In accordance with 10 CFR 50.91, a copy of this application, with Attachments, is being provided to the designated North Carolina and South Carolina officials.

If you should have any questions regarding this submittal, or require additional information, please contact Art Zaremba, Manager- Nuclear Fleet Licensing, at (980)373-2062.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 18, 2017.

Sincerely, Kelvin Henderson Senior Vice President - Nuclear Corporate MKL Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-up)

3. Proposed Technical Specification Bases Changes (Mark-up)

U.S. Nuclear Regulatory Commission RA-17-0001 Page 3 cc (with Attachments):

C. Haney, USNRC Region II - Regional Administrator J. 0. Austin, USNRC Senior Resident Inspector - CNS G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Zeiler, USNRC Senior Resident Inspector - HNP G. R. Eatmon, USNRC Senior Resident Inspector - RNP E. L. Crowe, USNRC Senior Resident Inspector - ONS M. C. Barillas, NRR Project Manager - HNP D. Galvin, NRR Project Manager - RNP M. Mahoney, NRR Project Manager- CNS and MNS A L. Klett, NRR Project Manager - ONS A Gantt, Chief, Bureau of Radiological Health (SC)

A Wilson, Attorney General (SC)

W. L. Cox, Ill, Section Chief, North Carolina Department of Health and Human Services, RP Section (NC)

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management (SC) to RA-17-0001 Page 1of4 Attachment 1 DESCRIPTION AND ASSESSMENT

Subject:

Application to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules"

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 4.0 ENVIRONMENTAL EVALUATION to RA-17-0001 Page 2of4

1.0 DESCRIPTION

The proposed change affects the Technical Specifications (TS) for Catawba Nuclear Station (CNS), Units 1 and 2; McGuire Nuclear Station (MNS), Units 1 and 2; Oconee Nuclear Station (ONS), Units 1, 2 and 3; Shearon Harris Nuclear Power Plant (HNP), Unit 1; and H. 8. Robinson Steam Electric Plant (RNP), Unit No. 2. The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the TS to clarify the use and application of the TS usage rules, as described below:

CNS, MNS, ONS, and RNP Section 1.3 are revised to clarify "discovery."

CNS, MNS, ONS, and RNP Section 1.3 are revised to discuss exceptions to starting the Completion Time at condition entry.

CNS, MNS, and RNP Limiting Condition for Operation (LCO) 3.0.4.b are revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

CNS, MNS, ONS and RNP Surveillance Requirement (SR) 3.0.3, and HNP TS 4.0.3, are revised to allow application of SR 3.0.3 (4.0.3 for HNP) when an SR has not been previously performed and to clarify the application of SR 3.0.3 (4.0.3 for HNP).

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Duke Energy has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016 (ADAMS Accession Number ML16060A441). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-529. Duke Energy has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to CNS, MNS, ONS, HNP, and RNP, and justify this amendment for the incorporation of the changes to each plant's TS.

2.2 Variations TSTF-529 includes TS markups for each plant design. Note that CNS, MNS, HNP, and RNP are Westinghouse designs. ONS is a Babcock & Wilcox (B&W) design.

Duke Energy is proposing the following variations from the TS changes described in TSTF-529:

HNP has not converted to the NUREG-1431 improved Standard Technical Specifications (STS). Therefore, the general format and numbering convention associated with the current TS has been retained. In particular, HNP TS 4.0.3 is the corresponding TS associated with the TSTF-529 changes for STS SR 3.0.3. In addition, the HNP TS do not include a section on Completion Times similar to STS TS 1.3.

Hence, the STS TS 1.3 changes included in TSTF-529 are not applicable.

TSTF-529 includes administrative changes associated with STS LCO 3.0.4.b, clarifying that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c were introduced into the STS via TSTF-359. TSTF-359 has not been adopted by ONS or HNP; hence, this portion of the TSTF-529 change is not applicable to ONS or HNP.

TSTF-529 includes a change to STS TS 1.3 that includes a discussion of inoperable diesel generators in relation to Required Action 8.2 of LCO 3.8.1, "AC Sources -

to RA-17-0001 Page 3 of 4 Operating". Consistent with the plant design, ONS LCO 3.8.1 does not address diesel generators. As described in ONS Bases 3.8.1 , the onsite standby power sources are the Keowee Hydro Units (KHU), and the standby buses can also receive power from a combustion turbine generator at the Lee Steam Station through a dedicated 100 kV transmission line. Therefore, the proposed change for ONS TS 1.3 includes an alternate example. Specifically, Required Action C.2.2.1 of ONS LCO 3.8.1 regarding the Lee Combustion Turbine (LCT) is discussed as an example, in lieu of Required Action 8 .2.

These variations do not affect the applicability of TSTF-529 or the NRC staffs safety evaluation to the proposed license amendment.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Duke Energy requests adoption of TSTF-529, "Clarify Use and Application Rules," that is an approved change to the standard technical specifications (STS), into the Catawba Nuclear Station (CNS), Units 1 and 2, McGuire Nuclear Station, Units 1 and 2 (MNS), Oconee Nuclear Station (ONS), Units 1, 2 and 3, Shearon Harris Nuclear Power Plant (HNP), Unit No. 1, and H. 8 . Robinson Steam Electric Plant (RNP), Unit No. 2 Technical Specifications (TS). The proposed change revises CNS, MNS, ONS, and RNP Section 1.3, "Completion Times," CNS, MNS, and RNP TS Limiting Condition for Operation (LCO) 3.0.4, CNS, MNS, ONS, and RNP TS Surveillance Requirement (SR) 3.0.3, and HNP TS 4.0.3, to clarify the TS use and application rules. Section 1.3 is modified to clarify the concept of "discovery" that an LCO is not met, and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 (TS 4.0.3 for HNP) is revised to allow application of SR 3.0.3 (4.0.3 for HNP) when an SR has not been previously performed.

Duke Energy has evaluated whether or not 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to CNS, MNS, ONS, and RNP Section 1.3, and CNS, MNS, and RNP LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to CNS, MNS, ONS, and RNP SR 3.0.3 (TS 4.0.3 for HNP) states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes do not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

to RA-17-0001 Page 4of4

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 change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

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

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

Response: No.

The proposed change clarifies the application of TS 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 (TS 4.0.3 for HNP) is revised to allow application of SR 3.0.3 when an SR has not been previously performed, if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 (TS 4.0.3 for HNP) while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, Duke Energy 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or 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 change 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 change.

to RA-17-0001 Attachment 2 Proposed Technical Specification Changes (Mark-up)

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

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

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

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks , such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating ," Required Action 8 .2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition 8 concurrent with inoperability of redundant required feature(s) ." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

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

(continued)

Catawba Units 1 and 2 1.3-1 Amendment Nos. 173/165

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef discovery of the situation that required entry into the Condition, unless otherwise specified .

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

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this (continued)

Catawba Units 1 and 2 1.3-2 Amendment Nos. 173/165

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

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; or

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 if appropriate; exceptions to this Specification are stated in the individual Specifications; or

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

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

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

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)."

If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required (continued)

Catawba Units 1 and 2 3.0-2 Amendment Nos. 2351231

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

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

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and the risk impact shall be managed.

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

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

(continued)

Catawba Units 1 and 2 3.0-6 Amendment Nos. 235/231

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

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

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

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing ,

without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

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

(continued)

McGuire Units 1 and 2 1.3-1 Amendment Nos. 1841166

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition , unless otherwise specified .

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

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this (continued)

McGuire Units 1 and 2 1.3-2 Amendment Nos. 1841166

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

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; or

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 if appropriate; exceptions to this Specification are stated in the indi¥idual Specifications; or

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

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

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

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

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

(continued)

McGuire Units 1 and 2 3.0-2 Amendment Nos. 2211203

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

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

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and the risk impact shall be managed.

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

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

(continued)

McGuire Units 1 and 2 3.0-4 Amendment Nos. 2061186

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

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

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation NEW Paragraph: (e.g., inoperable equipment or variable not within limits) that requires ntering an ACTIONS Condition unless otherwise specified, providing the un*

in a MODE or specified condition stated in the Applicability of the LCO. equired Actions must be completed prior to the expiration of the spec ed Completion Time. An ACTIONS Condition remains in effect and th Required Actions apply until the Condition no longer exists or the

.....N_E_W_P_a_r-ag

_ r_a_p.....

h""' : * . ..&i::.

a ot within the LCO Applicability.

INSERT ONS TS ations are discovered that require entry into more than one

...1_.3_ _ _ _ _ _~ ition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition Once a Condition has been entered, subsequent trains, subsystems, , unless components, or variables expressed in the Condition, discovered to be otherwise inoperable or not within limits, will not result in separate entry into the specified Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

, unless otherwise specified OCONEE UNITS 1, 2, & 3 1.3-1 Amendment Nos. 300, 300, & 300

INSERT ONS TS 1.3 Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.

While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action C.2.2.1, requires energizing both standby buses from the Lee Combustion Turbine (LCT) via the isolated power path. The Completion Time states, "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsequent discovery of deenergized standby bus." In this case the 1-hour Completion Time does not begin until the conditions in the Completion Time (i.e., discovery of the deenergized standby bus) are satisfied.

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

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

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillanc A risk evaluation shall be performed for any Surveillance delayed gr r than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and the risk impact shall be__ m_a_n_a_e _d_._ _ _ __..__ ____

The delay period is only If the Surveillance is not performed applicable when there is a t immediately be declared not met, an reasonable expectation the be entered. surveillance will be met when When the Surveillance is performed "p~emrfro-ci rr rm

""""e"'"dc:n.11:>"1""-.:rcr,..,..,,,~.....,.."tTn:r----'

Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

OCONEE UNITS 1, 2, & 3 3.0-4 Amendment Nos. 356, 358 , & 357 I

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation, unless otherwise stated In an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the surveillance or between performances of the surveillance, shall be failure to meet the LCO. Failure to perform a surveillance within the specified surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance Interval.

4.0.3 If it is discovered that a survemance was not performed within its specified surveillance Interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the Omit of the specified survelHance interval, whichever is greater. This delay period is permitted to allow performance of the surveillance. risk evaluation shall be performed for any surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the risk impact shaH be managed.

If the surveillance Is not perfo within the delay period, the LCO must Immediately be declared not met. and the appli le ACTION requirements must be met.

When the surveillance is perform d within the delay period and the surveillance criteria are not met, the LCO must imm lately be declared not met. and the applicable ACTION requirements must be met 4.0.4 Entry into an OPERATIONAL MO E or other specified condition shall not be made unless the Surveillance Requirement(s) a *ated with the Limiting Condition for Operation has been performed within the stated . . . Is provisiOn shall not prevent passage The delay penod 1s only applicable red to comply with ACTION requirements. when there is a reasonable 4.0.5 Deleted expectation the surveillance will be met when performed .

SHEARON HARRIS - UNIT 1 3140-2 Amendment No. 141

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation CLCOs) s~cify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with eacti stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for COIDP.leting a R~ired Action. It is referenced to the t:ftne e# disc tion <e.g .

inoperable equipnent or variabl NEW paragraph ) that requires entering an ACTIONS on on un ess therwise specified. providing the unit is in a MOOE or spec ed condition stated in the Applicability of the LCO. Required Actions must be completed prior to the e iration of the s~cified

~letion Time. An ACTI Condition remains in effect and the Required Act NEW Paragraph: INSERT RNP TS 1.3 r

~~~~~ ~

If situations are discovered that require entry into more than one Condition at a time within a single LCO <multiple Conditions> . the R~ired Actions for each Condition must be performed within the associated Co@ll>letion Time. When in multiple Conditions. separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

Once a Condition has been entered. subseque .

subsystems. ~s. or variables expres , unl~ss otherwise Condition. discovered to be inoperable or n_s.. . ;. p_e_c1_fie_d_ _ _. . . .

will DQ1 result in separate entry into the Condition. unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure. with Completion Times based on initial entry into the Conditio

, unless otherwise specified (continued)

HBRSEP Unit No. 2 1.3*1* Arnenchent No. 116

INSERT RNP TS 1.3 Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.

While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

. LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 a. When the associated ACTIONS to be entered permit continued (continued) operation in the HOOE or other specified condition in the Applicability for an unlimited period of time. or

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. 'i"'-BMP811IP"1ll~

exeeptions te this Speeifieation are ~tated ~~IM!lvtfklal Speeif1eat1ens. or if appropriate (exceptions to

c. When an allowance is stated in the i this specification are stated parameter. or other Specification. in the individual This Specification shall not prevent cha ._sp_e_c_ifi_ca_ti_o_ns_);_o_r _ ____,

specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under adlllinistrative control solely to perform testing required to demonstrate its OPERABIUTY or the OPERABILITY of other equipaent. This is an exception to LCO 3.0.2 for the system returned to service under acb1n1strat1ve control to perfona the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to an be entered. This is exception to LCO 3 .0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15.

safety Function Determination Program (SFDP).

If a loss of safety function is determined to exist by this program. the appropriate Conditions and Required Actions of the LCO in which (continued)

HBRSEP Unit No. 2 3.0*2 Amenctnent No. ~. 293

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT CSR) APPLICABILITY SR 3.0.1 SRs shall be met during the HODES or other specif;ed conditions in the Applicability for indivi<ktal LCOs. unless otherwise stated in the SR. Failure to meet a Surveillance.

whether such failure is experienced during the performance of the Surveillance or between perfonnances of the Surveillance. shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified F~y for each SR 1s met 1f the Surveillance 1s perfOf'Ed within 1.25 times the interval specified in the Frequency, as 11easured from the previous perfor11ance or as measured from the time a specified condition of the Frequency is met.

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

If a Completion Time requires periodic performance on a "once per . . . *basis , the abOve Frequency extension applies to each perfonnance after the initial performance.

Exc;eptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not perfonned within its specified Fr~. then compliance with the r~ire.ent to declare the LCO not met 1111.Y be delayed. from the time of discovery. up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified F~ncy, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be perfonaed for any Survei 11 ance 1ayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impa The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

(continued)

HBRSEP Unit No. 2 3.0*4 AEndlllent No. 229 to RA-17-0001 Attachment 3 Proposed Technical Specification Bases Changes (Mark-up)

(For Information Only)

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LC Os LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

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

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered The Required Actions establish those remedial measures that mu be taken within specified Completion Times when the requirements f an LCO are not met. This Specification establishes that:

a. Completion of the Requir * *

ecified Completion Times constitutes complia , unless otherwise n; and specified.

b. Completion of the Require ctions 1s not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable.

(Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS .) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Catawba Units 1 and 2 B 3.0-1 Revision No .~

LCO Applicability B 3.0 BASES 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. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the 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. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

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 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 LCO phrase, "Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ..."

does not mean that an actual change in load must be commenced by the end of the 1-hour period (Reference 1). The action initiated at the end of the 1-hour period may be administrative in nature, such as preparing shutdown procedures. If at the end of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , corrective measures which would allow exiting LCO 3.0.3 are not complete, but there is reasonable assurance that they will be completed with enough time remaining to still allow for an orderly unit shutdown, if required, commencing a load decrease may be delayed until that time. The time limits specified to r:eaGA-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.

Catawba Units 1 and 2 B 3.0-3 Revision No. 2

LCO Applicability B 3.0 BASES c.

LCO 3.0.3 (continued)

Au 1t shutdown required in accordance with LCO 3.0.3 may be inated and LCO 3.0.3 exited if any of the following occurs:

The LCO is now met~

A Condition exists for which the Required Actions have now been

b. The LCO is no performed longer applicable, ; f" ACTIONS ex1s ' or o 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.

entering The time limits of Specification . entered hours for the u it ........rw::r"I....--~

entering MODE 5 when a shutdown i equired during MODE 1 operat on. If the

*sin a lower MODE of peration when a shutdown is req red, the time lim1 GhiRg th ext lower MODE applies. If a lowe MODE is

...n~:\SG in less time th allowed, however, the total allowabl time to

~- MODE 5, or o r applicable MODE, is not reduced. F xample, if MODE 3 is in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for ~IGHllHQ entered MODE 4 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for raa~M MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Th remedial measures are completed that would permit a return to M a penalty is not incurred by having to a lower MO entering enter less than the total time allowed.

In MODES 1, 2, 3, and 4, .3 provides actions for Conditions not covered in other Specifica enter he 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 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.

Catawba Units 1 and 2 B 3.0-4 Revision No. J

LCO Applicability 8 3.0 BASES LCO 3.0.3 (continued)

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, "Spent Fuel Pool (SFP) Water Level."

LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel 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, 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 .14 of "Suspend movement of irradiated fuel assemblies in the spent fuel 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 following entry into nditions are such that the requirements of the LCO would not be met, in cc~ h w wiilb,. LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

~

LCO .0.4.a allows entry into a MODE or other specified condition in the Applic ility with the LCO not met when the associated ACTIONS to be entere * * *

the MODE or other specified c~ndition i~ the A~plicability or~ will permit continued operation nee wi that mi within the MODE or other an i ited period of time in a . .. des an acceptable level of safety for specified conditio~

regard to the status of the unit before or after the MODE change.

ACTIONS Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made~*R-a(;G{)f(J4:m(:e->JW:*EA-l~.J>R:wu:~is-c:>J-U:ie Required .A.ctions.

and the Required LCO 3.0.4.b allows entry into a M Actions followed ndition in th Applicability with the LCO not met a after entry into the k assessme addressing inoperable systems and A i*c b*i*ty tion of the 1 11 results, determination of the accepta PP a

DE or other specified condition in the Applicability, and establishment o N EW p h*

management actions, if appropriate. aragrap

INSERT CNS Bases LCO 3.0.4 Catawba Units 1 and 2 8 3.0-5 Revision No. 3

INSERT CNS Bases LCO 3.0.4 For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

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

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification .

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1 . Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS . The sole purpose of this Specification is to provide an exce tion to LCO 3.0.2 (e.g., to not comply with the applicable INSERT CNS Bases ow the performance of SRs to demonstrate: LCO 3 .0 .5

a. ABILITY of the equipment being returned to service; or

b. BILITY of other equipment.

The administra ive controls ensure the time the equipment is returned to service in con ct with the requirements of the ACTIONS is limited to the time absolute! necessary to perform the allowed SRs. This Specification does not provi e time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILI TY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required .A.ctions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on-another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

Catawba Units 1 and 2 B 3.0-8 Revision No. l

INSERT CNS Bases LCO 3.0.5 (continuing same paragraph] LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

LCO 3.0.5 is not intended to be used repeatedly.

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

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

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

SR Applicability B 3.0 BASES SR 3.0.2 (continued)

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

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

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not completed within the specified Frequency. A eno of up to 24 ours or up to the limi ified Frequency, whichever is greater, applies from perform time that it is performed discovered that the Surveillance has not been pe rmed in accordance with SR 3.0.2, and not at the time that the specifi d Frequency was not met.

This delay period provides adequate time to Surveillances that have been missed. This delay period permits the completion a Surveillance before complying with Required Actions or other rem

measures that might precl completion of the Surveillance.

The b sis for this delay period includes consideration of unit con performance performance lanning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

Catawba Units 1 and 2 B 3.0-16 Revision No . .i

SR Applicability B 3.0 BASES SR 3.0.3 (continued)

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J . as modified by approved exemptions, etc.) is discovered to not have been performed when NEW Paragraph : specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a INSERT CNS time interval specified, the missed Surveillance should be performed at Bases SR 3 .0 .3 the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for th p repeatedly ,

Surveillances that become applicable as a consequen e of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for sis expected to be an infrequent occurrence. Use of the delay perio stablished by SR 3.0.3 is a flexibility which is not intended to be used

convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit cond itions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

Catawba Units 1 and 2 B 3.0-17 Revision No. 0

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

LCO B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LC Os LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times. unless otherwise stated.

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

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered , unless otherwise specified.

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

McGuire Units 1 and 2 B 3.0-1 Revision No. 84

LCO Applicability B 3.0 BASES LCO (continued)

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

This Specification delineates the time limits for placing the 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. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

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 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. If at the end of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , corrective measures which would allow existing LCO 3.0.3 are not complete, but there is reasonable assurance that corrective measures will be completed in time to still allow for an orderly unit shutdown, commencing a load decrease may be delayed until that time. The time limits specified to enter reasR-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, 7

b. The LCO is no longer applicable, b c. A Condition exists for which the Required Actions have now been performed7, or G d. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the McGuire Units 1 and 2 B 3.0-3 Revision No. 8i

LCO Applicability B 3.0 BASES Condition is initially entered and not from the time LCO 3.0.3 is exited.

McGuire Units 1 and 2 B 3.0-4 Revision No. 3i

LCO Applicability 8 3.0 BASES LCO (continued)

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering reaching the next lower MODE applies. If a lower MODE is entered reached 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 reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for entering reaching MODE 4 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for entering reaching MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . 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 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 3.7.13, "Spent Fuel Pool (SFP) Water Level."

LCO 3.7.13 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.13 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 .13 of "Suspend movement of irradiated fuel assemblies in the spent fuel 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 McGuire Units 1 and 2 8 3.0-5 Revision No. 8.:1-

LCO Applicability B 3.0 BASES LCO (continued) entered following entry into permit continued operation in the MODE or other specified condition in the Applicability will permit continued operation within the MODE or otherwise specified condition for an unlimited period of time. Compliance with ACTIONS with Required .A.ct1ons 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 such cases, entry into a MODE or other specified condition in the Applicability may be made and the Required Actions followed after entry into the Applicability.in accordanse with the pro'Jisions of the Required Actions.

For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION ("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessments, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specifications 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 1.182, "Assessing and Managing Risk McGuire Units 1 and 2 B 3.0-6 Revision No. 84-

LCO Applicability B 3.0 BASES LCO (continued)

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification .

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

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

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

b. The OPERABILITY of other equipment.

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

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

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no McGuire Units 1 and 2 B3.0-9 Revision No. 3:J.

LCO Applicability B 3.0 BASES Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system.

or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions.

This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

An e>eamplo of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the 8Rs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar e*ample of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the sarne trip system.

McGuire Units 1 and 2 B 3.0-10 Revision No. ~

SR Applicability 8 3.0 BASES SURVEILLANCE REQUIREMENT (continued)

"once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or the action accomplishes the function of the inoperable equipment in an alternative manner.

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

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to perform complete Surveillances that have been missed. This delay period permits the performance completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 McGuire Units 1 and 2 8 3.0-16 Revision No. I~

SR Applicability B 3.0 BASES SURVEILLANCE REQUIREMENT (continued) allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

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

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operationa l son¥eniense repeatedly to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed McGuire Units 1 and 2 B 3.0-17 Revision No.184-

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LC Os LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

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

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered The Required Actions establish those remedial measures that mu e taken within specified Completion Times when the requirements of a CO are not met. This Specification establishes that:

a. Completion of the Required Acti unless otherwise Completion Times constitutes compliance wi ~pecified .

~

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

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

In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

OCONEE UNITS 1, 2, & 3 B 3.0-1 Amendment Nos. 356, 358, & 357 I

LCO Applicability B 3.0 BASES LCO 3.0.3 corresponds to the actual condition of the unit. Sometimes, (continued) possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the 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.

It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

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 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. If at the end of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , corrective measures which would allow exiting LCO 3.0.3 are not complete, but there is reasonable assurance that corrective measures will be completed in time to still allow for an orderly unit shutdown, commencing a load decrease may be delayed until that time. The time limits specified to f8aGh lower MODES of operation permit the shutdown to proceed in a c rolled and orderly manner that is well within the specified maxi own rate and within the capabilities of the unit, assuming that enter imum 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

- --..MLlill b. The LCO is no longer applicable the actions of L . . ' ion 1.3, Completion Times.

A unit shutdown required in a~with LCO 3.0.3 may be terminated and LCO 3.0.3 exf~'d*;;;*~~~of the following occurs:

c

a. The LCO is now metf A Condition exists for which the Required Actions have now been performed.~

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.

OCONEE UNITS 1, 2, & 3 B 3.0-3 BASES REVISION DATED 10123103 I

LCO Applicability entered BASES LCO 3.0.3 he time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in (continued) en a shutdown is required during MODE 1 operation. If the la r MODE of operation when a shutdown is required, the ti entered reaching the next lower MODE applies. If a lower MODE is raaCAEK:I in less time than allowed, however, the total allowable time to ~O ~

ther applicable MODE, is not reduced . For example, if MOb~

J:eaGhEKI in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for

4 is the next 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , because the total time for MODE 4 is not reduce the allowable limit of 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . Thereto if remedial measures are .

completed that would permit a return to M DE 1, a penalty is not in entering by havin t a lower MODE of operat n in less than the total time wed.

enter In MODES 1, 2, 3, and 4, LCO 3.0.3 pr entering 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 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 3.7.11, "Spent Fuel Pool Water Level." LCO 3.7.11 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3. 7 .11 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 .11 of "Suspend movement of irradiated fuel assemblies in spent fuel 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 precludes placing the unit in a MODE or other specified condition stated in that Applicability (e.g., Applicability desired to be entered) when the following exist:

a. Unit conditions are such that the requirements of the LCO would not be met in the Applicability desired to be entered; and

b. Continued noncompliance with the LCO requirements, if the Applicability were entered, would result in the unit being required to OCONEE UNITS 1, 2, & 3 B 3.0-4 BASES REVISION DATED 10/23/03 I

ACTIONS LCO Applicability B 3.0 and the Required

_B_A_S_E_S-------------------~---A~onsfullowedafter LCO 3.0.4 exit the Applicability desired to be entered to comply it entry into the (continued) Actions. Compliance with hat pe i Applicability.

operation of the unit for an unlimited period of time i a MODE or other

. - - - - - - - - - - -.-5lle.c;m*~d condition provides an acceptable level of s fety for continued NEW Paragraph : on. This is without regard to the status of the unit before or after the INSERT ONS Bases LCO 3.0.4 change. Therefore, in such cases, entry int MODE or other 1

'---------r----=~......e d condition in the Applicability may be made m accordance with the provisions of the Required Actions. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. The exceptions allows entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time. Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

LCO 3.0.4 is only applicable when entering MODE 4 from MODE 5, MODE 3 from MODE 4, MODE 2 from MODE 3, or MODE 1 from MODE 2.

Furthermore, LCO 3.0.4 is applicable when entering any other specified condition in the Applicability associated with operating in MODES 1, 2, 3, or

4. The requirements of LCO 3.0.4 do not apply in MODES 5 and 6, or in other specified conditions of the Applicability (unless in MODES 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, changing MODES or other specified conditions while in an ACTIONS Condition, in compliance with LCO 3.0.4 or where an exception to LCO 3.0.4 is stated, is not a violation of SR 3.0.1 or SR 3.0.4 for those Surveillances that do not have to be performed due to the associated inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

OCONEE VNfT.S 1, 2, & 3 B 3.0-5 BASES REVISION DATED 10.£23/03 I

INSERT ONS Bases LCD 3.0.4 For example, the provisions of LCO 3.0.4 may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION {"Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4 is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

LCO Applicability B 3.0 BASES (continued)

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

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

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testino..til..£1JamllW'1r.aUL_ ___

OPERABILITY. This Specification does not provide tim INSERT ONS Bases other preventive or corrective maintenance. ______

LCO 3.0.5 An example of demonstrating the OPERA.BILITY of the equipment being returned to service is reopening a containment isolation 1Jal1Je that has been closed to comply wlth a Required Action , and must be reopened to perform the required testing .

A.n example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to pre'lent the trip function from occurring during the performance of requir:ed testing on another channel in the other trip system. f>,, similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions. When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be OCONEE UNITS 1, 2, & 3 B 3.0-6 BASES REVISION DATED :t.OJ23J03 I

INSERT ONS Bases LCO 3.0.5

[continuing same paragraph] LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

LCO 3.0.5 is not intended to be used repeatedly.

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

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

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

SR Applicability B 3.0 BASES SR 3.0.2 The 25% extension does not significantly degrade the reliability that results (continued) from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.

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

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational con*..enience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified. rf d pe orme SR 3.0.3 SR 3.0.3 establishes the flexibility t defer declaring affected equipment inoperable or an affected variabl utside the specified limits when a Surveillance has not been compl&ted within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. perform This delay period provides an adequate time to Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or oth remedial measures that might preclude

of the Surveillance performance performance OCONEE UNITS 1, 2, & 3 B 3.0-13 BASES REVISION DATED 10!20!11 I

SR Applicability B 3.0 BASES SR 3.0.3 The basis for this delay period includes consideration of unit conditions, (continued) adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

NEW Paragraph: repeatedly INSERT ONS R 3.0.3 provides a time limit for, and allowances fo ce o, Bases SR 3. 0.3 urveillances that become applicable as a consequence of MODE hanges imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 i a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. ' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component.

OCONEE UNITS 1, 2, & 3 B 3.0-14 Amendment Nos. 356, 358, & 357

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

APPLICABILITY BASES 3.0.4 (Continued) operationwhent INSERT HNP Bases 3.0.4 nditionforOperationarenotmetandcontinued noncompliance t these conditions would resutt in a shutdown to comply with the ACTION requirements if. change ~n ~ODE~ ~ere and the ACTION requirements tion is to ensure that ~ell ~pe~o~ 1s not 1nit1ated followed after entry into the not e.ntered when corrective action 1s being taken to . .. restonng equipment to 0 ERABLE status or pa Apphcabihty Ith ACTION requirements t permit continued ope *on of the facility for an unlimited period of time provides an acceptable vel of safety for continu operation without regard to the status of the plant before or after MODE change. The re, in this case, entry into an OPERATIONAL MODE or other specified condition may be made * **

requiroments. rovisions of this specification should not, however, be interpreted as endorsing the failure o exercise ood practice in restoring systems or components to OPERABLE NEW Paragraph rtup.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.

3.0.5 This specification establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to 3.0.1 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

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

b. The OPERABILITY of other equipment The administrative controls ensure the time the equipme \IJSL!@ltl.lml84.IDJB8Clm:£t in conflict with the requirements of the ACTIONS is limited to the time a rform the required testing to demonstrate OPERABILITY. This vlde time to perform any other preventive or corrective maintenance.

An example of Etemenslfating tf:le OPERABILITY ef the equipment beiAfl retumed te sefYiee is reepening a GOfllaiAment isolatien valve that has been Glesed to eomply with Required Aetiens and must be reepened te peFferm the required testing.

!tit example ef demenstrating the OPERABILITY ef ether equipment is takfng an ineperable eh&F.Ael er trip system eut ef the tfipped eonditien te prevent the Clip fuAGtieA from eeeuffing during the performance ef ffHIUired testing en another ehennel in the ether trip system. A similar eample ef demenstrating the OPERABILITY ef ether equipment is taking an inepefflble ehannel or trip system eut of the IRpped eenditien te peFmit the legiG te funGtion and iAdiGate the apprepriate response during the performanee ef required testing on enether ehannel in the same trip system.

Revision 1 SHEARON HARRIS - UNIT 1 B 3/4 0-2 Amendment No. 84

INSERT HNP Bases 3.0.4 For example, Specification 3.0.4 may be used when the required ACTION to be entered states that an inoperable instrument channel must be placed in the trip condition within the required time limit. Transition into a MODE or other specified condition in the Applicability may be made in accordance with Specification 3.0.4 and the channel is subsequently placed in the tripped condition within the required time limit, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent ACTION allows the OPERABLE train to be placed in operation, use of Specification 3.0.4 is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

INSERT HNP Bases 3.0.5

[continuing same paragraph) Specification 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

Specification 3.0.5 is not intended to be used repeatedly.

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

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

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

APPLICA81Lf[Y BASES , - .

4.0.1 (Continued)

An example of this process is Awaliary Feedwatar (AFW) pump turbine maintenance during refueling that requires testing at steam pressures that cannot be obtained until the unit is at HOT SHUTDOWN conditions. However, If olher appn>p1iate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

4.0.2 The provislona of this specification establish the Hmft for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance Interval to facilitate survelllance scheduling and consideration of plant operating conditions that may not be suitable for conduclfng survellance; e.g.* transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveilances that are performed at each refueling outage and are specHiad with an 18 month surveilance Interval. It is not Intended that this provision be used repeatedly as a 88MenieRGe to extend aurveillance intervals t.Jand that spectfted for swvellances that are not performed during refueling outages. llcewlse. it Is not 1he intent that the 18-month interval survellances be performed during power operation unless it is consistent with safe plant operation. The limitation of SpecificaUon 4.0.2 is based on engineering judgment and the recognition that the most

probable result of any particular survelanca being performed is the verification of

,...eill~mm~wfth the Swveillance Requirements. This provision is aufllclent to ensure performed ensured ttvough surve1ance activHles Is not signlffcantly degraded beyond at obtained from the specified surveHlance Interval.

4.0.3 n 4.0.3 establshes the ftexibUity to defer declaring affected equipment nGP"'81llle or an affected variable outside the specified perform has not beel'1 within the specified surveillance Interval up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified swveillance interval. is greater. apples from the point In time that it Is discovered that the has not been performed in accorda performance .0.2, and not at the that the specified swvellance intervalwa1rnln"'n".-:-~~--

This delay period provides surveilances that have been missed. This delay period pennils the of a surveillance before complying with ACTION raqili'ementB or other remedial measures that might preclude GDR11P1811811:9' surveillance.

The basis for this delay period Includes consideration of unit conditions, adequ1111----,,.--L.--__,

planning. availability of personnel, the time required to perform the surveillance, performance significance of the delay in completing the required survelllance, and the recognition that the most probable result of any particulat aurvelHance being performed Is the verification of conformance with the requirements.

SHEARON HARRIS

UNIT 1 83/40-2b Amendment No. ~

APPLICABILITY

\ .

BASES ,~.

4.0.3 (Continued)

When a surveillance with a sLDVeiltance interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulalions (e.g., prior to entering OPERATIONAL MODE 1 after each fuel loading, or In accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) Is discovered to not have been performed when specified, Speciftcation 4.0.3 al1ows for the fUll delay ~ of u to the specified surveiUance interval to perform the surveillance. However, repeatedly ta time interval specified, the missed sulV8illance should be performed ble opportunity.

SUNeilancr.":~~---...i-:ei~~~'"'eotrtSeQ changes NEW Paragraph: INSERT F~- to--t HNP Bases 4.0 .3 intervals for surveill expected to be an infrequent occurrence. Use of the delay pen*oci~*lbllS Specification 4.0.3 is a flexibDily which is not Intended to be used'a&-8fHJDerallieAal cenvenienee to extend surveillance intervals. Whle up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveinance interval is provided to perform the missed surveillance, it ts expected that the missed surveillance will be performed at the first reasonable opportunity. The detennlnation of the first reasonable opportunity should include consideration of the impact on plant risk (tom delaying the surveilance as weH as any plant configuration changes required or shutting the plant down to perform the surveillance) and impact on any analysis assumptions, in addition to uni conditions, planning, availabillty of personnel, and the time required to perfonn the SUIV8illance. This risk impact should be managed through the program In place to implement 10 CFR 50.6S(a)(4) and its Implementation guidance, NRC Regulatory Gulde 1.182, 'Assessiig and Managing Risk Before Maiitenance Activities at Nuclear Power Plants.* This Regulatory Guide addresses consideration of temporary and aggregate risk inpacts, determination of risk management action thresholds, and risk management acllon up to and including plant shutdown. The missed survellance should be treated as an emergent conclUon.as discussed In the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate wtlh the impor1ance of the component. Missed survellances for impor1ant components should be analyzed quantitatively. If the results of the risk evaluation determine the risk Increase is significant, this evaluation should be used to detennine the safest course of action. All missed surveillances will be placed In the licensee's Corrective Action Program.

If a survetlance is not completed within the allowed delay period, then the equipment is considered Inoperable or the variable Is considered outside the speclfted limits and the time limits of the ACTION requirements for the applicable LCO begin immediately upon expiration of the delay period. If a surveillance Is failed within the delay period, then the equipment Is Inoperable or the variable Is outside the specified limitS, and the tine Omits of the ACTION requirements for the applicable LCO begin immecffately upon the failunt of the survelance.

Completion of the surveillance within the delay period allO\'Ved by this Specffication, or within the completion time of the ACTIONS, restores compliance with Specification 4.0.1 .

SHEARON HARRIS - UNIT 1 B3/40-2c Amendment No. -141

INSERT HNP Bases 4.0.3 Specification 4.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of Specification 4.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

LCO Applicability 83.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

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

LC03.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered The Required Actions establish those remedial measures that mu e

Completion Times when the requirements of an , unless otherwise Specification establishes that: specified .

~------

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specif1cation; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

(continued)

HBRSEP Unit No. 2 83.0-1 Revision No. 62

LCO Applicability 83.0 BASES LC03.0.3 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. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the 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. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems \.&-- - - - - .

components from service in lieu of other alternatives that enter ult in redundant systems or components being inoperable.

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 prepar for an orderly shutdown before initiating a change in unit operatic . This includes time to permit the operator to coordinate the reduction i electrical generation with the load dispatcher to ensure the stability a availability of the electrical grid. The time limits specified to Fea6h er MODES of operation permit the shutdown to proceed in a controUed 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.~

""- lb. The LCO is no longer applicable, I (continued)

HBRSEP Unit No. 2 B 3.0-3 Revision No. 28

LCO Applicability 83.0 BASES LCO 3.0.3 A Condition exists for which the Required Actions have (continued) now been performed d , or

.__,.,~*IONS exist that do not have exp pletion Times.

These Completion Times are applicable from the point in time that th~ Condition is initially entered and not from the time LCO ente ~ed entering exited.

enter The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in ODE entered when a shutdown is required during MODE 1 operation. If the nit is

a ower MODE of operation when a shutdown is required, the ti Ii for "l'e.1!1Mma the next lower MODE applies. If a lower MODE is reamEm less time than allowed, however, the total allowable time to ODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is enter in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for R!aGhin~OOE 4 i~ the ext 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for

MOt>l:.itlentermg ~ced fro e allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, medial measures are compl at would permit a return to MODE 1, a natty is not incurred by having t a lower MODE of operation in less the total time allowed. entering 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 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 3.7.12, "Fuel Storage Pool Water Level." LCO 3.7.12 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 3.7.12 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 3.7.12 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.

HBRSEP Unit No. 2 8 3.0-4 Revision No. 28

LCO Applicability B3.0 BASES 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 t he unit in a MODE or other specified condition stated in the following entry into Applicability (e.g., the .

ility desired to be entered) when unit onditions are su either uirements of the LCO would not be met, in rdance with 0 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

ACTIONS .0.4.a allows entry Into a MODE or other specified condition in the ility with the LCO not met when the associated ACTIONS to be enter pem:iit GGAtiRued operation in the MODE or other specified ition in the Applicability an unlimited perio . * . *. .

w* Requir:ed AGtions that perm tinued ope w~ll ~erm1t continued operation unlimited period of time in a MODE or sp

w1th1~ the MO~~ or other an acceptable level of safety for continued op

specified cond1t1on regard to the status of the unit before or after the c ange.

Therefore. in such cases, entry into a MODE or other specified condition in the Applicability may be madeJf*HK:GOl:uatlGe-Wfl.IHfMHlfGljRIA&-GHhe NEW Paragraph : RequiFed 1.Gtions.

INSERT RNP and the Required Actions Bases LCO 3.0.4 LCO 3.0.4.b allows entry into a MOD followed after entry into the Applicability with the LCO not met aft Applicability.

addressing inoperable systems and tJgynpt;nn;;JT'IQ:,o ggrnvsvaT'CRn:11'T"'-.:l'r"D"n:r" results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification 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 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.* Regulatory Guide 1.182 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.

(continued)

HBRSEP Unit No. 2 B 3.0-5 Revision No. 28

INSERT RNP Bases LCO 3.0.4 For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

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

RCS Specific Activity LCO Applicability B3.0 BASES LC03.0.4 The risk assessments rformed to justify the use of LCO 3.0.4.b (continued) usually only consider ystems and components. For this reason, LCO 3.0.4.c is typical! applied to Specifications which describe values and parameters (e.g., * * ,

PFessure, Moderator Temperat\JFe Coefficient), and may be applied to other Specifications based on NRC plant specific approval. LCO 3.0.4.c is applicable for LCO 3.4.16, RCS Specifac Activity.

The provisions of this SpeciflCation should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MOOE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Adions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LC03.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

(continued)

HBRSEP Unit No. 2 B 3.0-7 Revision No. 28

LCO Applicability B3.0 BASES LC03.0.5 (continued) The sole purpose of this Specification is to provide an exception (continued) to LCO 3.0.2 (e.g. , to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

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

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the r uirements of the ACTIONS is limited to the time absolutely ne INSERT RNP Bases LCO 3.0.5 This Specification does not provid 1 r corrective maintenance.

AA example of demoAstfating the OPERABILITY of the equipment being r:etumed to service is reopening a oontainment isolatioA val'le that has been Glosed te oomply t/Jith Required AGtiOAs aAd must be FeOpened te perfeFm the SRs.

AA example of demonstrating the OPERABILITY of ether equipment is takiAg an lnepeFable ehannel or trip system out of the tripped eondition to prevent the trip funGtion from OGGuFFing during the performance of an SR OA another ohannel in the other trip syetem. A similar e&mple of demonstrating the OPERABILITY of other equipment Is taking an inopeFSble GhanAel or trip system ollt of the tripped oonditiOA to permit the lagiG te function and indioate the appropriate response during the performaAGe of an SR on another ohannel in the same trip system.

LC03.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These required Actions may include entering the supported system's Conditions and Required Adions or may specify other Required Actions.

(continued)

HBRSEP Unit No. 2 B 3.0-8 Revision No. 28

INSERT RNP Bases LCO 3.0.5

[continuing same paragraph] LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

LCO 3.0.5 is not intended to be used repeatedly.

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

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

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

SR Applicability 83.0 BASES SR3.0.2 The requirements of regulations take precedence over the TS.

(continued) An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations.

The TS cannot in and of themselves extend a test interval specified in the regulations.

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

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

performed i - - - -

SR3.0.3 SR 3.0.3 establishes the flexibility to defe ring affected equipment U'4&jM\.n::r the specified limits when a Surveillance has not been GGA!tPleiteUWithin the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the Hmit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified F not met.

This delay period provides adequate time to Surv a performance have been missed. This delay period permits the

of a Surveillance before complying with Required Adions or other remedial measures that might preclude

the Surveillance.

The basis for this delay period includes conside~rn-n performance adequate planning, availability of personnel, (continued)

HBRSEP Unit No. 2 B 3.0-15 Revision No. 69

SR Applicability 83.0 BASES SR 3.0.3 the time required to perform the Surveillance, the safety (continued) significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or In accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time * *

illance should be performed at the NEW Paragraph:

INSERT RNP Bases SR 3.0.3 S 3. *

llowan repeatedly S rveillances that become applicable as a 01~sQUlmn:~..-M anges imposed by Required Actions.

Failure to comply with specified Frequenc*

infrequent occurrence. Use of the delay pe a flexibility which is not intended to be u1secr+as;-an-ooerabefl1at GOA'tfeAiense to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the SurveUlance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.* This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.

(continued)

HBRSEP Unit No. 2 8 3.0-16 Revision No. 52

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

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RA-17-0001, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

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RA-17-0001, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

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