TSTF-05-03, Transmittal of TSTF-482, Revision 0, Correct LCO 3.0.6 Bases, for NRC Consideration
| ML050480256 | |
| Person / Time | |
|---|---|
| Issue date: | 02/15/2005 |
| From: | Furio P, Infanger P, Morris B, Sparkman W B & W Owners Group, BWR Owners Group, Combustion Engineering Owners Group, Technical Specifications Task Force, Westinghouse Owners Group |
| To: | Boyce T NRC/NRR/DIPM |
| References | |
| TSTF-05-03 | |
| Download: ML050480256 (19) | |
Text
I T-ElCH1NICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVwITY February 15, 2005 TSTF-05-03 Thomas H. Boyce, Section Chief Technical Specifications Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
TSTF-482, Revision 0, "Correct LCO 3.0.6 Bases"
Dear Mr. Boyce:
Enclosed for NRC consideration is Technical Specification Task Force Traveler TSTF-482, Revision 0, "Correct LCO 3.0.6 Bases." This Traveler corrects an error in the Bases of LCO 3.0.6. The Bases of LCO 3.0.6 are inconsistent with the Technical Specifications.
The TSTF does not typically request NRC review of Bases changes. Utilities may make changes to their plant-specific Bases under the Technical Specification Bases Control Program.
However, given the importance of maintaining consistency between the Improved Standard Technical Specifications (ISTS) Section 3.0 use and application rules and plant-specific Technical Specifications, we believe that NRC review and approval of this change is warranted.
We request that the NRC review of TSTF-482 be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. This Traveler meets the exemption requirement in 10 CFR 170.1 1(a)(1)(iii),
in that it is "a means of exchanging information between industry organizations and the NRC for the specific purpose of supporting the NRC's generic regulatory improvements or efforts." In this case, the generic regulatory effort is the NRC's generic ISTS (NUREG-1430 through -1434).
The Owners Groups have not allocated funding for NRC review of this Traveler. If this change is not granted a fee waiver, please inform us so we may consider whether we wish to pursue or withdraw this change.
G)o- I4 11921 Rockville Pike, Suite 100, Rockville, MD 20852 X awn Phone: 301-984-4400, Fax: 301-984-7600 me aSw OWNERS'GROUP Email: tstf@excelservices.com Owners Group a \o Administered by EXCEL Services Corporation
TSTF 05-03 February 15, 2005 Page 2 Should you have any questions, please do not hesitate to contact us.
Wes Sp (WOG) Bert Morris (BWROG)
Patricia Furio (CEOG) Paul Infang BWOG)
Enclosure
- cc: NRC Document Control Desk
WOG-176, Rev. I TSTF^482, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Correct LCO 3.0.6 Bases NUREGs Affected: i 1430 WI 1431 Wj 1432 Ei 1433 Ev 1434 Classification: 2) Bases Only Change Recommended for CLIIP?: No Correction or Improvement: Correction NRC Fee Status: Exemption Requested Benefit: Improves Bases Industry
Contact:
Wes Sparkman, (205) 992-5061, wasparkmisouthemco.com 1.0 Description The Bases of LCO 3.0.6 are corrected to be consistent with the statements in LCO 3.0.6.
2.0 Proposed Change The LCO 3.0.6 Bases are revised from "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)" to "LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS)" (emphasis added).
In addition, two editorial corrections are made to the LCO 3.0.6 Bases to make the sentences gramatically correct.
3.0 Background
The Bases must be consistent with the Specifications. The LCO 3.0.6 Bases have contained this incorrect statement since Revision 0 of the ISTS NUREGs.
IS-Feb-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
WOG-176, Rev. I TSTF482, Rev. 0 4.0 Technical Analysis LCO 3.0.6 states, '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."
However, the LCO 3.0.6 Bases states "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)." The Bases also do not specify that this is only true if the support system has an LCO in the Technical Specifications. This is inconsistent with the Specification and incorrect.
LCO 3.0.2 states that when an LCO is not met, the Conditions and Required Actions must be entered.
LCO 3.0.6 requires entering the Conditions and Required Actions for support systems when those support systems have an LCO in the Technical Specifications. This change makes the Bases consistent with the Specifciations.
5.0 Reeulatory Analysis 5.1 No Significant Hazards Consideration This section is not required for Bases changes.
5.2 Anplicable Reaulatorv Requirements/Criteria This section is not required for Bases changes.
6.0 Environmental Consideration This section is not required for Bases changes.
7.0 References None.
Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: Braidwood Revision
Description:
Original Issue Owners Group Review Information Date Originated by OG: 24-Jun-04 Owners Group Comments:
(No Comments)
Owners Group Resolution: Approved Date: 27-Jul-04 I5-Feb-05 Traveler Rev. 3. Copyright (C)2005, EXCEL Services Corporation. Use by EXCEL Services associates. utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission isprohibited.
WOG-176, Rev. 1 TSTF 482, Rev. 0 OG Revision 0 Revision Status: Closed TSTF Review Information TSTF Received Date: 27-Jul-04 Date Distributed for Review: 02-Nov-04 OG Review Completed: G BWOG iZ WOG D CEOG E BWROG TSTF Comments:
(No Comments)
TSTF Resolution: Superceeded Date:
OG Revision 1 Revision Status: Active Revision Proposed by: WOG Revision
Description:
Revised LCO 3.0.6 to specify in the first paragraph of LCO 3.0.6, "LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS)."
The phrase 'a support system LCO" was added to Revision 0 to further clarify the sentence. The justification was revised to reflect this change.
Owners Group Review Information Date Originated by OG: 08-Dec-04 Owners Group Comments:
(No Comments)
Owners Group Resolution: Approved Date: 08-Dec.04 TSTF Review Information TSTF Received Date: 05-Dec-04 Date Distributed for Review: 05-Dec.04 OG Review Completed: i BWOG W WOG Wi CEOG v BWROG TSTF Comments:
(No Comments)
TSTF Resolution: Approved Date: 08-Dec-04 NRC Review Information NRC Received Date: 15-Feb-05 Affected Technical Specifications LCO 3.0.6 Bases LCO Applicability 15-Feb-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-482, Rev. 0 LCO APPLICABILITY 8 3.0 BASES LCO 3.0.5 (continued)
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 required testing 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 required testing on another channel in the same trip system.
ILCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have an support system 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 declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.
Rev. 3.0, 03/31/04 STS B 3.0-8 BWOG STS B 3.0-8 Rev. 3.0, 03/31/04
TSTF482, Rev. 0 LCO APPLICABILITY B 3.0 BASES LCO 3.0.6 (continued)
This loss of safety function does not require the assumption of additional I single failures or loss of offsite power. Since operations -are being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).
When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately I addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.
LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.
Test Exception LCOs [3.1.8, 3.1.9, and 3.4.191 allow specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.
Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
BWOG STS B 3.0-1 1 Rev. 3.0, 03/31/04
TSTF482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
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 required testing 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 required testing on another channel in the same trip system.
I LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have an support system 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 isjustified 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 declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.
B 3.0-8 Rev. 3.0, 03/31/04 STS WOG STS B 3.0-8 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11 which is in turn supported by System 5.
EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System I of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and 11.1 If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
TMA TV" U System 0 SysSm 2 1Sync § Syst"m 2 Sam I ytmI St1 ems s Systs.,S I Sy3ste"m110 System I System I 5pbm12 sy System System12 System S Iystami Syyst 13 Sysyt 13 Cyan 14 SySystem Sytm7 System ?
77' 'Y Is opts~
Sye5i
[ Figure B 3.0-1 Configuration of Trains and Systems ]
This loss of safety function does not require the assumption of additional I single failures or loss of offsite power. Since operations is-are being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken B 3.0-10 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.0-10 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued) into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).
When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.
LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.
Test Exception LCOs [3.1.8 and 3.4.19] allow specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.
Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.
Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.
WOG STS B 3.0-1 1 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
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 required testing 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 required testing on another channel in the same trip system.
I LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have an support system 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 declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.
However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.
This may occur immediately or after some specified delay to perform B 3.0-8 Rev. 3.0, 03/31/04 CEOG STS STS B 3.0-8 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System I of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and 1 1. ]
If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
TRAIN A TRAIN a
,System 8 System 4 SySyte4 System9 Sysem System 2 System 2 Syuton 10 Systems Syte
. -5 System 11 System 11 Sod Spyst I System12 ISystem 12 System 13 System 13 Syste 3 Ibasnd System 14 System 7 1System 14 System 15 System is
[ Figure B 3.0-1 Configuration of Trains and Systems]
This loss of safety function does not require the assumption of additional I single failures or loss of offsite power. Since operations is-are being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).
Rev. 3.0, 03/31/04 B 3.0-10 Rev. 3.0, 03/31/04 STS CEOG STS B 3.0-10
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.
LCO 3.0.7 Special tests and operations are required at various times over the unit's life to demonstrate performance characteristics, to perform maintenance activities, and to perform special evaluations. Because TS normally preclude these tests and operations, special test exceptions (STEs) allow specified requirements to be changed or suspended under controlled conditions. STEs are included in applicable sections of the Specifications. Unless otherwise specified, all other TS requirements remain unchanged and in effect as applicable. This will ensure that all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed or suspended to perform the special test or operation will remain in effect.
The Applicability of an STE LCO represents a condition not necessarily in compliance with the normal requirements of the TS. Compliance with STE LCOs is optional.
A special test may be performed under either the provisions of the appropriate STE LCO or the other applicable TS requirements. If it is desired to perform the special test under the provisions of the STE LCO, the requirements of the STE LCO shall be followed. This includes the SRs specified in the STE LCO.
Some of the STE LCOs require that one or more of the LCOs for normal operation be met (i.e., meeting the STE LCO requires meeting the specified normal LCOs). The Applicability, ACTIONS, and SRs of the specified normal LCOs, however, are not required to be met in order to meet the STE LCO when it is in effect. This means that, upon failure to meet a specified normal LCO, the associated ACTIONS of the STE LCO CEOGSTSB 3.-11Rev.3.0 03/1/0 CEOG STS B 3.0-1 1 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
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 required testing 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 required testing on another channel in the same trip system.
I LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have an suDport system 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 plant 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 declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.
However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.
This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, 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.
ST B 30-8Rev.3.0 03/1/0 BWRI BWR/4 STS B 3.0-8 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
Syslem 8 System 4 Sy-toom4 System S System s 8System 2
Systeen 2 System 2 System 1 ayto11 SytmS *'"",M I'1I Sysem1 system I Syt 12 Syst"i 12 System 13 I
Syts I yte m 13 S wm6System iS Sees System 3 Samt 14 ISystm 14 System 7 Sustm is Systm is
[ Figure B 3.0-1 Configuration of Trains and Systems]
This loss of safety function does not require the assumption of additional I single failures or loss of offsite power. Since operations is-are being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).
BWR/4 STS B 3.0-1 0 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO isthe LCO for the supported system.
LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.
Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.
Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
BWR/4 STS B 3.0-1 1 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
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 required testing 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 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 supported systems that have an support system 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 plant 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 declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Required Actions.
However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.
This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, 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.
Rev. 3.0, 03/31/04 STS B 3.0-8 BWRI6 STS BWR/6 B 3.0-8 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued)
TRAIN A TRAIN B Sm4 I System ysstem4 System 4 l S System 2 Systy1 2 Systemu I System 10 System 11 SytmISystem 11 Sum I System I System s System 12 System 12 System 12 System S Syttemy t System 13 System 3 SSyste 14 ysn 14 System St System 7 S e Syste 1 System IS
[ Figure B 3.0-1 Configuration of Trains and Systems]
This loss of safety function does not require the assumption of additional I single failures or loss of offsite power. Since operations is-are being restricted in accordance with the ACTIONS of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONS for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the definition of OPERABILITY).
When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is
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BWR/6 STS B 3.0-1 0 Rev. 3.0, 03/31/04
TSTF-482, Rev. 0 LCO Applicability B 3.0 BASES LCO 3.0.6 (continued) solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.
LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.
Special Operations LCOs in Section 3.10 allow specified TS requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
The Applicability of a Special Operations LCO represents a condition not necessarily in compliance with the normal requirements of the TS.
Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
BWR/6 STS B 3.0-1 1 Rev. 3.0, 03/31/04