Text

Transmittal of TSTF-529, Revision 2, Clarify Use and Application Rules
	ML14014A330
Person / Time
Site:	Technical Specifications Task Force
Issue date:	01/14/2014
From:	Croft W, Gustafson O, Loeffler R, Slough R; BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force, Westinghouse
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-14-02, TSTF-529, Rev 2
	Download: ML14014A330 (155)
	v • d • e

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF January 14, 2014 TSTF-14-02 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-529, Revision 2, "Clarify Use and Application Rules" Enclosed for NRC review is Revision 2 of TSTF-529, "Clarify Use and Application Rules."

TSTF-529 is applicable to all plant types.

TSTF-529 was revised to reflect the discussions between the NRC and the TSTF at the July 18, 2013 public meeting.

The TSTF requests that the NRC bill the Boiling Water Reactor Owners' Group and the Pressurized Water Reactor Owners Group for the review of this Traveler.

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

Robert Slough (PWROG/W)

Richard A. Loeffler (BWROG)

Otto W. Gustafson (PWROG/CE)

Wendy E. Croft (PWROG/B&W)

Enclosure cc:

Michelle Honcharik, Licensing Processes Branch, NRC Robert Elliott, Technical Specifications Branch, NRC

TSTF-529, Rev. 2 BWROG-121, Rev. 0 NUREGs Affected:

Clarify Use and Application Rules Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Changes Marked on ISTS Rev 4.0 See attached justification.

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

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

27-May-10 Owners Group Comments (No Comments)

Date: 17-Jun-11 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

25-Aug-11 Date Distributed for Review 25-Aug-11 TSTF Comments:

(No Comments)

Date: 21-Sep-11 TSTF Resolution:

Approved OG Review Completed:

BWOG CEOG WOG BWROG NRC Review Information NRC Received Date:

21-Sep-11 See the Revision 1 description.

16-Oct-12 NRC Requests Changes: TSTF Will Revise NRC Comments:

Final Resolution:

Final Resolution Date:

TSTF Revision 1 Revision Status: Closed Revision Proposed by:

TSTF 14-Jan-14 Copyright(C) 2014, 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-529, Rev. 2 BWROG-121, Rev. 0 TSTF Revision 1 Revision Status: Closed At an October 16, 2012 TSTF/NRC meeting to discuss TSTF-529, the TSTF agreed to revise TSTF-529, Revision 0. The following changes are made to the indicated changes numbered in justification:

1. Revision 0 changed Section 1.3 and the LCO 3.0.2 Bases to define and give an example of "time of discovery." The NRC pointed out that LCO 3.0.2 uses the term "discovery" instead of "time of discovery."

Revision 1 proposes to revise Section 1.3 to use the term "discovery" instead of "time of discovery," and to reference two NRC documents that clarify this concept in the Section 3.0 Bases, which together resolve the issue.

2. Revision 0 changed Section 1.3 for NUREG-1432 (Westinghouse plants) to discuss application of Completion Times for certain existing I&C Notes. In Revision 1, the insert is revised and made applicable to all ISTS NUREGs to explain the exception "unless otherwise specified" in the Section 1.3 statement that Completion Times are referenced to the discovery of a situation that requires entering an ACTIONS Condition unless otherwise specified.

3. No change.

4. No change.

5. Revision 1 replaces the proposed LCO 3.0.5 and associated Bases change to address the NRC concern that the Revision 0 proposal was not focused on testing to restore Operability.

6. Revision 0 revised the Bases of LCO 3.0, LCO 3.0.2, and SR 3.0 to state that the LCO and SR usage rules were applicable to Section 3.0 of the TS and to Chapter 5 when invoked. Enforcement Guidance Memorandum (EGM) 12-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests," issued by the NRC on February 24, 2012, and Regulatory Issue Summary 2012-10, " NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests,"

issued August 23, 2012, stated the NRC position that the Section 3.0 rules were not applicable to Chapter 5 requirements. The proposed change is removed from Revision 1 and any necessary clarifications to the Bases will be included in a Traveler that addresses the EGM and RIS.

7. Revision 0 replaced the phrase "operational convenience" in the TS Bases in four locations (LCO 3.0.2, LCO 3.0.3, SR 3.0.2 and SR 3.0.3). As agreed by the TSTF and NRC, Revision 1 focuses the change on removing the phrase from SR 3.0.2 and SR 3.0.3. The TSTF and NRC will hold a public meeting to discuss replacement, definition, or clarification of the term "operational convenience" in LCO 3.0.2 and LCO 3.0.3.

8. No change.

9. No change.

10. No change.

11. No change.

12. No change.

Revision

Description:

14-Jan-14 Copyright(C) 2014, 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-529, Rev. 2 BWROG-121, Rev. 0 TSTF Revision 1 Revision Status: Closed Owners Group Review Information Date Originated by OG:

24-Jan-13 Owners Group Comments (No Comments)

Date: 13-Feb-13 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

13-Feb-13 Date Distributed for Review 13-Feb-13 TSTF Comments:

(No Comments)

Date: 28-Feb-13 TSTF Resolution:

Approved OG Review Completed:

BWOG CEOG WOG BWROG NRC Review Information NRC Received Date:

28-Feb-13 NRC accepted for review on 6/20/2013.

18-Jul-13 NRC Requests Changes: TSTF Will Revise NRC Comments:

Final Resolution:

Final Resolution Date:

TSTF Revision 2 Revision Status: Active At the July 18, 2013 TSTF/NRC public meeting, the TSTF agreed to make the following changes to address NRC concerns:

Item 1: Removed the proposed references and added the following to Section 1.3, "The Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the declaration that an LCO is not met and an ACTIONS Condition is entered, unless otherwise specified."

Item 2: Revised the inserted paragraph to address NRC comments item 3: The TSTF removed the change to LCO 3.0.4 and revised the LCO 3.0.4 Bases.

Item 4: No changes made in Revision 2.

Item 5: The TSTF agreed to not revise LCO 3.0.5 and to include the clarification in the Bases.

Item 6: No changes made in Revision 2.

Item 7: No changes made in Revision 2.

Revision

Description:

Revision Proposed by:

NRC 14-Jan-14 Copyright(C) 2014, 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-529, Rev. 2 BWROG-121, Rev. 0 Affected Technical Specifications TSTF Revision 2 Revision Status: Active Item 8: The TSTF revised the paragraph to use consistent terminology.

Item 9: No changes made in Revision 2.

Item 10: No changes made in Revision 2.

Item 11: The justification and markup were revised to reflect the removal of the LCO 3.0.5 rewrite in Change Number 5, while retaining the proposed Revision 1 Bases changes.

Item 12: The proposed Bases insert was revised based on the NRC comments.

Owners Group Review Information Date Originated by OG:

26-Aug-13 Owners Group Comments (No Comments)

Date: 16-Sep-13 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

16-Sep-13 Date Distributed for Review 18-Sep-13 TSTF Comments:

(No Comments)

Date: 18-Nov-13 TSTF Resolution:

Approved OG Review Completed:

BWOG CEOG WOG BWROG NRC Review Information NRC Received Date:

14-Jan-14 1.3 Completion Times LCO 3.0.2 Bases LCO Applicability SR 3.0.2 Bases LCO Applicability LCO 3.0.3 Bases LCO Applicability SR 3.0.3 Bases LCO Applicability 14-Jan-14 Copyright(C) 2014, 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-529, Rev. 2 BWROG-121, Rev. 0 LCO 3.0.4 LCO Applicability LCO 3.0.4 Bases LCO Applicability LCO 3.0.5 Bases LCO Applicability 14-Jan-14 Copyright(C) 2014, 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-529, Rev. 2 Page 1 1.0 Description The proposed change will revise Sections 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) and the TS Bases for Section 3.0, "LCO Applicability" and "SR Applicability," to clarify the use and application of the existing TS usage rules. The proposed change clarifies issues that have resulted in NRC Task Interface Agreement requests, a licensee request for an interpretation of the TS, licensee violations, and many licensee and NRC inspector questions.

2.0 Proposed Change The following changes to the TS and Bases are proposed:

1.

Section 1.3 is modified to clarify "discovery."

2.

Revisions are made to Section 1.3 to discuss exceptions to starting the Completion Time at condition entry.

3.

Limiting Condition for Operation (LCO) 3.0.4.a Bases are modified to clarify that Required Actions must be followed after entry into the Modes and other specified conditions in the Applicability. An example is added to the Bases.

4.

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. The LCO 3.0.4.a Bases are revised to support the clarification.

5.

The LCO 3.0.5 Bases are revised to clarify its application.

6.

This change was removed in Revision 1.

7.

The Bases of Surveillance Requirement (SR) 3.0.2 and SR 3.0.3 are revised to remove the term "Operational Convenience."

8.

Changes are made to the Bases of LCO 3.0.3 and SR 3.0.3 to use consistent terminology.

9.

The LCO 3.0.3 Bases are corrected to state that a unit shutdown may be terminated and LCO 3.0.3 exited if the LCO is no longer applicable.

10.

The LCO 3.0.4.c Bases are modified to replace a misleading TS reference.

11.

The LCO 3.0.5 Bases are modified to clarify that LCO 3.0.5 should not be used if there are other alternatives to demonstrate that an LCO is met and maintain compliance with Actions. The LCO 3.0.5 Bases examples are revised.

TSTF-529, Rev. 2 Page 2

12.

The SR 3.0.3 Bases are modified to clarify when SR 3.0.3 may be applied and to state expectations for applying SR 3.0.3 when an SR has not been performed for an extended period.

A model application is included in the proposed change. The model may be used by licensees desiring to adopt TSTF-529 following publication by the NRC of the Notice of Availability in the Federal Register.

The model application requests NRC review and approval of the changes to the TS Bases.

The TSTF has taken the conservative position that changes to the LCO 3.0 and SR 3.0 Bases have the potential to alter the application of the TS. In accordance with Paragraphs b.1 and d of the TS Bases Control Program, the proposed Bases changes must be reviewed and approved by the NRC prior to implementation. Following approval of the plant-specific license amendment request to adopt the Traveler, licensees will issue the revised Bases pages in accordance with the licensee TS Bases Control Program.

3.0 Background In January and February 2009, the Technical Specifications Task Force (TSTF) and NRC met to discuss questions and possible ambiguities on the application of the Improved Standard Technical Specifications (ISTS). The topics for discussion were gathered from both the NRC and the industry. In all, ten areas of ambiguity were discussed. In almost all cases, the TSTF and the NRC reached agreement on the application of the ISTS or agreed on a process to reach agreement.

The TSTF agreed to prepare a TSTF Traveler for NRC review to clarify the TS use and application rules in LCO 3.0 and SR 3.0, to document areas of agreement in the TS and Bases, and present proposed resolutions for the remaining areas under question. The TSTF queried the industry and identified several areas in Section 1.3, LCO 3.0 and SR 3.0 that would benefit from clarification. These clarifications are generally minor or editorial, but routinely generate questions from licensee and NRC staff and are, therefore, worthy of correction.

Revision 0 of the Traveler was submitted on September 21, 2011. In September 2012, the NRC provided to the TSTF a draft of a letter giving reasons why the Traveler could not be accepted for review. A public meeting was held between the TSTF and the NRC on October 16, 2012, to discuss the NRC concerns. The Traveler was revised to address those concerns.

At a July 18, 2013 public meeting, the NRC provided comments on Revision 1 of the Traveler. This revision addresses those comments.

4.0 Technical Analysis 4.1 Revise Section 1.3 to Clarify "Discovery" LCO 3.0.2 states, "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6."

TSTF-529, Rev. 2 Page 3 The LCO 3.0.2 Bases state, "LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met." Section 1.3 states that the Completion Time is "referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits)." Understanding the term "discovery" is fundamental in applying Required Actions and associated Completion Times.

There sometimes is confusion by both NRC and industry staff on the meaning of the term "discovery." Much of this confusion results from differing guidance depending on whether one is considering TS compliance or reportability. Except in Section 1.3, the TS use the term "discovery," but Section 1.3 uses the phrase "time of discovery." This creates confusion because the reportability regulations, 10 CFR 50.72 and 10 CFR 50.73, and their associated guidance use the phrase "time of discovery" with a different meaning.

Therefore, it is worthwhile to revise Section 1.3 to use the term "discovery" instead of "time of discovery" consistent with LCO 3.0.2 and the remainder of the TS and Bases.

The proposed change makes the following revision to the "Description" section of Section 1.3:

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 declaration that an LCO is not met and an ACTIONS Condition is entered....

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.

(The text in italics is added, and struck-out text is removed.)

The inserted text is taken from the NRC guidance in NRC Inspection Manual, Part 9900:

Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety" (Reference 2). Section 4.8, "Operator Awareness and Responsibilities," states:

"A senior licensed operator on the operating shift crew with responsibility for plant operations makes the declaration of operability, i.e., 'makes the call' on whether an SSC described in TSs is operable or inoperable."

TSTF-529, Rev. 2 Page 4 This position is also consistent with the historical NRC position. For example, in a memorandum from H. L. Thompson, Director, Division of Licensing, to R. Starostecki, Director, Division of Reactor Projects, Region 1, dated August 9, 1985 (Reference 1 and ), Mr. Thompson stated, "It is NRR's position that the time limitation of action requirements are applicable from the point in time that it is recognized that the requirements of a limiting condition of operation are not met. This is as noted by your example and proposed interpretation. It was also noted in your memo that this issue is further complicated by recent trends in NRC enforcement which cite the historical inoperability of equipment as a factor in determining the significance of loss of function violations."

This Section 1.3 revision in conjunction with the LCO 3.0.2 Bases makes it clear that discovery is when a senior licensed operator on the operating shift crew with responsibility for plant operations declares an LCO not met and a Condition is entered.

To our knowledge, the proposed change does not represent a point of disagreement between the NRC and the industry.

4.2 Revise Section 1.3 to Discuss Exceptions to Starting the Completion Time at Condition Entry Section 1.3 states:

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. (emphasis added.)

The phrase, "unless otherwise specified," is not explained in Section 1.3 or in the LCO 3.0.2 Bases. (Note that Section 4.1, above, describes a proposed change to the above paragraph that does not affect this change.)

There are a number of examples of specifying a different reference point for the start of the Completion Time other than discovery.

All ISTS 3.8.1, "AC Sources - Operating," Required Action B.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.

BWR/4 and BWR/6 ISTS 3.3.1.1A and 3.3.1.1B, "Reactor Protection System Instrumentation," Table 3.3.1.1, contains a Note which states, "When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains RPS trip capability." It is

TSTF-529, Rev. 2 Page 5 recognized that performing the required testing makes the channel inoperable, but entering the Required Actions and starting the Completion Time is deferred.

Similar Notes appear in the BWR/4 and BWR/6 SR tables for Control Rod Block Instrumentation, BWR/4 Feedwater and Main Turbine High Water Level Trip Instrumentation, EOC-RPT Instrumentation, ATWS-RPT Instrumentation, ECCS Instrumentation, RCIC System Instrumentation, Primary Containment Isolation Instrumentation, Secondary Containment Isolation Instrumentation, BWR/6 RHR Containment Spray System Instrumentation, BWR/6 SPMU System Instrumentation, BWR/4 LLS Instrumentation, BWR/6 Relief and LLS Instrumentation, BWR/4 ISTS [MCREC] System Instrumentation, BWR/6 ISTS

[CRFA] System Instrumentation, and LOP Instrumentation.

Westinghouse ISTS 3.3.1A and 3.3.1B, "Reactor Trip System Instrumentation,"

Conditions D, E, K, L,M, N, O, and P, contain Notes similar to, "One channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing and setpoint adjustment." It is recognized that placing the train in bypass renders the train inoperable, but starting the Completion Time is deferred in accordance with the Notes.

Westinghouse ISTS 3.3.2A and 3.3.2B, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," Conditions C, D, E, G, H, I, and K, contain Notes similar to, "One channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing and setpoint adjustment." It is recognized that placing the train in bypass renders the train inoperable, but starting the Completion Time is deferred in accordance with the Notes.

Many BWR Actions in Section 3.3, "Instrumentation," have Completion Times similar to, "[1] hour from discovery of loss of initiation capability for features in both divisions." It is recognized that the Completion Time starts, not on Condition entry, but on meeting the condition in the Completion Time.

The lack of explanation has resulted in questions by licensees and inspectors. For example, if a clause that provides a delayed start time is no longer applicable or the time period in the clause has expired, it is unclear if the Completion Time is referenced to entry into the Condition or to the point at which the clause is exited. To address these questions, a paragraph is added to Section 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 declaration 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 which 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

TSTF-529, Rev. 2 Page 6 be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.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.

The first sentence in the added paragraph is discussed in Section 4.1.

Two other sentences in Section 1.3 are revised to establish internal consistency:

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.

and 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.

In a complementary change, the Bases of LCO 3.0.2 are revised to eliminate a minor discrepancy between the TS (Section 1.3) and the Bases. Section 1.3 states that a Completion Time is referenced to the time of discovery of a situation that requires entering an ACTIONS Condition unless otherwise specified (emphasis added).

LCO 3.0.2 makes a similar statement but without the qualifier, "unless otherwise specified." Therefore, the LCO 3.0.2 Bases are revised to state:

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 changes are needed to be consistent with existing ISTS, as discussed above.

4.3 Clarifications to LCO 3.0.4.a Bases LCO 3.0.4.a states:

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;...

In the memorandum "Final Task Interface Agreement - Reevaluation of Implementation of Limiting Condition for Operation 3.0.4a, 'Mode Change Limitations,' At Palisades Nuclear Plant (TIA 2009-005)," dated September 17, 2009 (NRC Agencywide Document Access and Management System (ADAMS) Accession Number ML092540032), the

TSTF-529, Rev. 2 Page 7 NRC issued a response to a Task Interface Agreement (TIA) request documenting the Staff position regarding the application of Technical Specification LCO 3.0.4.a. The NRCs stated position in the response to TIA 2009-005, was "...whilecompleting the TS required actions to be entered before conducting a mode transition with inoperable equipment establishes the basis for continued operation, the completion of those actions is not a requirement for compliance with LCO 3.0.4a."

The Bases of LCO 3.0.4 are revised to clarify the intent of LCO 3.0.4.a, as described in the TIA response, as follows:

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into permit continued operation in the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with ACTIONS Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in 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 accordance with the provisions of the Required Actions.

The LCO 3.0.4 Bases are also revised to add an example of the application of LCO 3.0.4.a. The example addresses a frequent question by clarifying that it is not necessary that every possible set of Required Actions allow continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time, only that a set of Required Actions allow continued operation. For example, it is not necessary to assume that the licensee does not perform the Required Actions, such as placing a channel in trip or starting a piece of equipment. The proposed Bases insert states:

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 in 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.

TSTF-529, Rev. 2 Page 8 4.4 Editorial Clarification to LCO 3.0.4.b LCO 3.0.4 contains three options, labeled paragraphs a, b, and c. Paragraph a ends with a semicolon and Paragraph b ends with ", or". This presentation is consistent with the ordered list format as described TSTF-GG-05-01, "Writers Guide for Plant-Specific Improved Technical Specifications," except that Paragraph b should end with a semicolon, such as "; or".

LCO 3.0.4.b states:

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 The separation of the majority of the text from the "or" conjunction by the phrase regarding exceptions has misled some readers to interpret the "or" statement to only apply to the phrase regarding exceptions and to believe that LCO 3.0.4.a, b, and c apply concurrently. The sentence is clarified by placing the statement regarding exceptions in parenthesis and to replace the ending comma with a semicolon:

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 The Bases are also revised to clarify this point. The introductory paragraph of LCO 3.0.4 is revised to insert the word "either" as follows: "in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c" (Added text is in italics).

4.5 Revise the LCO 3.0.5 Bases to Clarify its Application LCO 3.0.5 states:

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 testing required to demonstrate OPERABILITY.

LCO 3.0.5 provides a necessary flexibility to facilitate restoring equipment to Operability (or to perform Surveillances required to verify Operability).

LCO 3.0.5 discusses equipment removed from service which is to be returned to service.

This addresses the majority of situations, however, it does not address all situations in

TSTF-529, Rev. 2 Page 9 which LCO 3.0.5 could be used. In some TS, ACTIONS involve the placement of redundant or alternate equipment or trains into service, or the repositioning (opening or closing) of components. An example is the Pressurizer Power Operated Relief Valves (PORVs) for Pressurized Water Reactors (PWRs). If a PORV is inoperable, the Required Action is to close the associated block valve in order to isolate the inoperable PORV.

Once the PORV is repaired, it may be necessary to stroke the PORV in order to demonstrate its Operability. The closed block valve must be opened so that system pressure is restored to the PORV, allowing the PORV to be stroked. The Required Action to close the block valve does not clearly fall under the LCO 3.0.5 allowance because it does not involve "equipment removed from service or declared inoperable."

In a letter dated May 18, 2011, Calvert Cliffs Nuclear Power Plant LLC (CCNPP) requested a written interpretation from the NRC staff on the application of LCO 3.0.5 to six Required Actions in which use of LCO 3.0.5 would not involve restoring the component to service to perform required testing (NRC ADAMS Accession No. ML11145A085). The NRC responded on December 20, 2011 (NRC ADAMS Accession No. ML112940645). The NRC stated:

"The NRC staff concludes that CCNPP TS Required Action 3.3.7.B.1, 3.3.8.A.1, 3.4.11.A.1, 3.4.11.C.1, 3.7.3.A.1, and 3.7.8.A.1 are within the scope of the administrative controls applied by LCO 3.0.5 for the purpose of realignment of components needed for conducting the operability testing on equipment, so long as the testing could not be conducted while relying on TS Required Actions. This includes the repositioning of redundant or alternate equipment or trains previously manipulated to comply with the TS Required Action. The staff further concludes that LCO 3.0.5 would apply in all cases to systems or components in Section 3 of the licensee's TSs."

The LCO 3.0.5 Bases are revised to reflect the NRC staff interpretation of LCO 3.0.5 by adding the following paragraph:

In an interpretation dated December 20, 2012 (NRC Agencywide Document Access and Management System (ADAMS) Accession No, ML11145A085), the NRC concluded that the administrative controls in LCO 3.0.5 would 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.

TSTF-529, Rev. 2 Page 10 4.6 This change was removed in Revision 1 of the Traveler.

4.7 Revise the Bases of SR 3.0.2 and SR 3.0.3 to Remove the Term "Operational Convenience" The term "operational convenience" appears four times in the Bases of each ISTS NUREG: in the Bases of LCO 3.0.2, LCO 3.0.3, SR 3.0.2, and SR 3.0.3. It does not appear in the Specifications.

The ISTS LCO 3.0.2 Bases state:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. (emphasis added).

The ISTS LCO 3.0.3 Bases state:

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. 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. (emphasis added).

The ISTS SR 3.0.2 Bases state:

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. (emphasis added).

The ISTS SR 3.0.3 Bases state:

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 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

TSTF-529, Rev. 2 Page 11 missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should... (Emphasis added).

Use of the term "operational convenience" in the Bases of the TS has changed and been expanded from its original use and intent, and the revised Bases have created difficulty in interpreting and applying the current guidance. Bases revisions are proposed to replace this term in SR 3.0.2 and SR 3.0.3 with information reflecting its original intent.

The term "operational convenience" first appeared in several 1987-era documents. Its first use is in the model Bases markups attached to Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," dated June 4, 1987 (Reference 3). Copies of the applicable Model PWR Bases pages from GL 87-09,, are included as Attachment 2 for reference. In the two GL 87-09 Bases sections where the term "operational convenience" is used, it is equated with "(routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable."

Also, the operational convenience concept is only linked to intentional entries into Actions that directly contain a shutdown requirement. As stated, "It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable" (emphasis added). The term "operational convenience" was not utilized in the Bases for Surveillance Requirement 4.0.2 (now called SR 3.0.2) or in the Bases for SR 4.0.3 (now SR 3.0.3).

The question of potential misinterpretation of the proposed words in GL 87-09 was raised almost immediately by the industry. For example, in a meeting held with Carolina Power

& Light on September 17, 1987 (Reference 4 and Attachment 3), when the intent of the GL words were still fresh, the NRC clarified that the term was only intended to limit intentional entry into ACTIONS when the situation involves redundant systems being out of service. The NRC staff stated that, for both Bases sentences, "the point of clarification is that the last echelon of defense should not be removed from service such that this would invoke a prompt shutdown action requirement, in lieu of other alternatives that would not result in redundant systems being out of service simultaneously."

The third 1987 document (Reference 5 and Attachment 4) is an Inspection Manual Part 9900 Technical Guidance document, "Standard Technical Specifications (STS)

Section 3.0.3 Limiting Conditions for Operation." Similar to the above, the operational convenience words are linked to situations in which redundant safety systems would be out of service, and it explains that the concern is for situations in which entry into ACTIONS would show a disregard for plant safety.

In the 1991 time frame, during the development of Revision 0 of the ISTS NUREGs, the above described concept was broken down into several separate sentences in the LCO 3.0.2 Bases. Additional changes made during the development of the ISTS (some at the request of the industry) resulted in the term "operational convenience" becoming

TSTF-529, Rev. 2 Page 12 separated from the concept of "(routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable." It was also separated from the link to Actions that directly involve a shutdown requirement. In addition, the term was introduced into the SR 3.0.2 Bases in circumstances in which the GL 87-09 intent was not applicable.

The June 1992 "Proof and Review" version of the ISTS NUREGs also added the term to the SR 3.0.3 Bases, again in circumstances that are not consistent with the original intent, as the SR usage rules are not related to entry into ACTIONS.

The TSTF is not proposing to remove the term "operational convenience" in LCO 3.0.2 or LCO 3.0.3 at this time. At the October 16, 2012 public meeting between the TSTF and the NRC regarding TSTF-529, the NRC and TSTF agreed to hold a public meeting to discuss the concept of operational convenience in LCO 3.0.2 and LCO 3.0.3 and to discuss needed changes or clarifications.

The proposed change revises the Bases of SR 3.0.2 and SR 3.0.3 to restore the original intent and to eliminate the incorrect application of the term "operational convenience."

The Bases of SR 3.0.2 are revised to state:

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.

This change does not alter the intent, while eliminating the inconsistent use of the term "operational convenience."

The Bases of SR 3.0.3 are revised to state:

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 operational convenience repeatedly to extend Surveillance intervals.

This change does not alter the intent, while eliminating the inconsistent use of the term "operational convenience." The term "repeatedly" is added for consistency with SR 3.0.2 and to avoid the Bases being in apparent conflict with the allowance in SR 3.0.3.

4.8 Revise the Bases of LCO 3.0.3 and SR 3.0.3 to Improve Terminology The LCO 3.0.3 Bases uses the term "reaching" when describing a transition to a lower MODE. The term "entering' is more accurate and is the commonly used term in the TS for MODE transitions. The term is ambiguous as it's not clear whether the MODE conditions in Table 1.1 are met. In seven locations in the LCO 3.0.3 Bases, the term "reaching" a MODE is replaced with the term "entering" a MODE.

TSTF-529, Rev. 2 Page 13 The SR 3.0.3 Bases use the term "completing" with respect to an SR four times.

Specification SR 3.0.3 uses the term "performing" a Surveillance. The term "performed" is defined in the "Description" section of Specification 1.4, "Use and Application, Frequency," as specifically determining the ability to meet the acceptance criteria. While the terms (complete and perform) have the same meaning in this context, the terms "perform" or "performance" are substituted in the Bases for "complete" or "completion" to improve consistency between the Specifications and the Bases.

These changes do not represent any change in intent, but are made for consistency within the ISTS.

4.9 Correct LCO 3.0.3 Bases to Acknowledge a Unit Shutdown may be Terminated and LCO 3.0.3 Exited if the LCO is No Longer Applicable The LCO 3.0.3 Bases state:

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met,

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

c. 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.

This list is incomplete. As stated in LCO 3.0.2, "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated." The list in the LCO 3.0.3 Bases does not acknowledge that a unit shutdown may be terminated and LCO 3.0.3 exited if the LCO is no longer applicable (i.e., the LCO that was not met which lead to entry into LCO 3.0.3).

The proposed change adds to the list a new paragraph b which states, "The LCO is no longer applicable," and the subsequent list items are renumbered.

This change does not represent any change in intent, but is made for consistency within the ISTS.

4.10 Modify the LCO 3.0.4.c Bases to Correct a Misleading TS Reference The Bases to LCO 3.0.4.c state:

The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g.,

[Containment Air Temperature, Containment Pressure, MCPR, Moderator

TSTF-529, Rev. 2 Page 14 Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.

Although the list of specifications to which LCO 3.0.4.c is typically applied is in brackets (i.e., plant specific), the parenthetical phrase is misleading. In the ISTS, LCO 3.0.4.c is only applied to one specification, "RCS Specific Activity." This specification is not listed in the Bases and the listed specifications in the ISTS allow application of LCO 3.0.4.c. For consistency within the ISTS, the bracketed list of Specifications is replaced with "(e.g., RCS Specific Activity)."

4.11 Modify the LCO 3.0.5 Bases to Clarify that LCO 3.0.5 Should Not be Used if there are Other Alternatives that Maintain Compliance with Actions.

Many specifications contain provisions which allow Required Actions to not be followed to facilitate repair or testing. For example, the instrumentation specifications may allow channels to be placed in bypass, the containment air lock specification contains an Actions Note which allows entry and exit to perform repairs, and the containment isolation valve specification contains an Actions Note which allows isolated penetration flow paths to be unisolated under administrative control. In these cases, the risks and benefits of not following the Required Action were generically evaluated and accepted and, in some cases, additional restrictions are applied (such as a time limit for keeping an instrument channel in bypass).

When the specification does not provide an allowance to not follow a Required Action in order to establish equipment is Operable, LCO 3.0.5 may be used.

LCO 3.0.5 states:

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 testing required to demonstrate OPERABILITY.

Because LCO 3.0.5 applies in many circumstances, it's not possible to generically evaluate every possible application and, therefore, its use should be minimized. As stated in the LCO 3.0.5 Bases, 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.

TSTF-529, Rev. 2 Page 15 In cases in which the Specification's ACTIONS or SRs contain allowances that permit testing to establish an LCO is met, licensees should use those features instead of LCO 3.0.5 as those features have been specifically evaluated and are consistent with LCO 3.0.2. In order to clarify this point, the LCO 3.0.5 Bases are modified by adding the following:

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.

The proposed change is consistent with the intent of LCO 3.0.5 and provides additional guidance to licensees to avoid misinterpretation.

In a related change, an incorrect example in the LCO 3.0.5 Bases is replaced. In NUREG-1431, -1432, -1433, and -1434 (Westinghouse, Combustion Engineering (CE),

Boiling Water Reactor (BWR)/4 and BWR/6 plants), the existing example cites the containment isolation valve specification. As noted above, the containment isolation valve specification contains an Actions Note which eliminates the need to use LCO 3.0.5 to unisolate a penetration to perform Operability testing. Therefore, the example is removed. A new example is added to all of the ISTS NUREGs that describes manual valves closed to isolate Reactor Coolant System Pressure Isolation Valve leakage. The other existing examples in the LCO 3.0.5 Bases regarding instrument channels are revised and retained. The example recognizes that NUREG-1431 (Westinghouse plants) contains Required Actions Notes which allow channel testing in lieu of using LCO 3.0.5.

4.12 Modify the SR 3.0.3 Bases to Clarify when SR 3.0.3 May be Applied As stated in SR 3.0.1, SR 3.0.3 is an exception to the requirement that a Surveillance be performed within the specified Frequency. SR 3.0.3 states, "If it is discovered that a Surveillance was not performed..." SR 3.0.3 is not an exception to the requirement for SRs to be met during the Modes or other specified conditions in the Applicability. This is a key consideration in the application of SR 3.0.3.

The terms "met" and "performed" are defined in Section 1.4, "Use and Application, Frequency" of the ISTS. It states:

The use of "met" or "performed" in these instances conveys specific meanings. A Surveillance is 'met' only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being 'performed,' constitutes a Surveillance not 'met.' 'Performance' refers only to the requirement to specifically determine the ability to meet the acceptance criteria.

TSTF-529, Rev. 2 Page 16 The Bases of SR 3.0.3 also state that SR 3.0.3 is an exception to performing the SR within the specified Frequency, not to the requirement an SR be met. The Bases state; The basis for this delay period includes... the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

The Bases of SR 3.0.3 also state:

If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Therefore, if an SR has not been performed within the specified Frequency and it is known that the acceptance criteria of the SR are not met, then the equipment is inoperable and SR 3.0.3 cannot be applied.

NRC Inspection Manual, Part 9900: Technical Guidance, "Operability Determinations &

Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," Section 3.9 states:

The discovery of a degraded or nonconforming condition may call the operability of one or more SSCs [structures, systems, or components] into question. A subsequent determination of operability should be based on the licensees

'reasonable expectation,' from the evidence collected, that the SSCs are operable and that the operability determination will support that expectation. Reasonable expectation does not mean absolute assurance that the SSCs are operable. The SSCs may be considered operable when there is evidence that the possibility of failure of an SSC has increased, but not to the point of eroding confidence in the reasonable expectation that the SSC remains operable. The supporting basis for the reasonable expectation of SSC operability should provide a high degree of confidence that the SSCs remain operable. It should be noted that the standard of

'reasonable expectation' is a high standard, and that there is no such thing as an indeterminate state of operability; an SSC is either operable or inoperable.

This concept of "reasonable expectation" is directly applicable to the question of whether a licensee may apply SR 3.0.3 to an SR that has not been performed within its specified Frequency because in both cases the question to be addressed is whether the associated equipment is believed to be Operable or that variables are within limits. If the licensee has a reasonable expectation (a high standard) that performance of the SR will confirm that the equipment is Operable or a variable to be verified is within limits, then SR 3.0.3 may be applied to the SR which has not been performed. If the licensee does not have this reasonable expectation, then under SR 3.0.1 the SR is not met and the associated LCO is not met.

In most cases, discovery of an SR that has not been performed within the specified Frequency occurs when a single performance has been missed. In that case, a review of

TSTF-529, Rev. 2 Page 17 the surveillance history and equipment performance may be sufficient to provide a reasonable expectation that the Surveillance will be met when performed.

However, in some cases an SR, or portions of an SR, may not have been performed for more than one Frequency period, or may not have ever been performed. In that case, establishing a reasonable expectation that the SR is met is more difficult. The licensee will consider other indications, tests, or activities for an indication of whether the SR will be met when performed. These indications must be on the affected components and not inferred from the performance of similar components. The rigor of determining whether there is a reasonable expectation an SR will be met when performed should increase based on the length of time since the last successful performance. For long delays or for SRs that have never been performed, a more rigorous evaluation, documented in sufficient detail to explain the basis for the determination, should be performed.

The preceding discussion is proposed to be captured in the SR 3.0.3 Bases with the following addition:

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.

The proposed Bases wording is consistent with the existing requirements of SR 3.0.3 and the philosophy of "met" and "performed" SRs as described in Section 1.4 of the TS.

The proposed Bases are also consistent with the intent of SR 3.0.3 as stated in GL 87-09.

It states, "It is overly conservative to assume that systems or components are inoperable

TSTF-529, Rev. 2 Page 18 when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement." The fact that SRs must be met in order to apply SR 3.0.3 to SRs that have not been performed within their specified Frequency implements the assumption that systems or components are operable.

Conclusion The proposed changes are consistent with the current intent of Section 1.3, and LCO 3.0 and SR 3.0 and their associated Bases and will increase the clarity and allow consistent application of the ISTS.

5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The Technical Specifications Task Force (TSTF) has evaluated whether or not a significant hazards consideration is involved with the proposed generic change 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 change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) and the TS Bases for Section 3.0, "LCO Applicability" and "SR Applicability," to clarify the use and application of the TS usage rules. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (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. The Bases of LCO 3.0.4.a are modified to clarify that Required Actions must be followed after entry into the Modes and other specified conditions in the Applicability. The SR 3.0.2 and SR 3.0.3 Bases are revised to remove the term "operational convenience," and the LCO 3.0.3 and SR 3.0.3 Bases are revised to use terminology consistent with the corresponding TS. The LCO 3.0.5 Bases are modified to clarify its applicability to all TS Section 3 Required Actions, and that LCO 3.0.5 should not be used if there are other alternatives to demonstrate Operability that maintain compliance with Actions. An inaccurate example in the LCO 3.0.5 Bases is replaced and another example is revised. The SR 3.0.3 Bases are modified to clarify when SR 3.0.3 may be applied and to state expectations for applying SR 3.0.3 when an SR has not been performed for an extended period.

TSTF-529, Rev. 2 Page 19 The changes to Section 1.3 and 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 Bases changes clarify the appropriate application of the existing TS requirements. Since the proposed change does 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.

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. The proposed change clarifies the current application of the specifications. The clarification of the term "discovery" in Section 1.3 does not change the current timing or actions to be taken when LCOs are not met. The changes to the TS Bases clarify the application of the existing requirements.

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 Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. As a result, plant safety is either improved or unaffected. The proposed changes to the Bases clarify the application of the existing TS requirements and, as a result, have no significant effect on a margin of safety.

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

Based on the above, the TSTF concludes that the proposed change presents no significant hazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

TSTF-529, Rev. 2 Page 20 5.2 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations, Paragraph 50.36, requires TS and describes LCOs and SRs. The proposed change clarifies the implementation of the TS required by 10 CFR 50.36.

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

6.0 Environmental Consideration A review has determined that 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.

7.0 References

1. Memorandum from H. L. Thompson (NRC) to R. Starostecki (NRC), "Technical Specification Interpretation," dated August 9, 1985 (Attachment 4).

2. NRC Inspection Manual, Part 9900: Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety".

3. Generic Letter 87-09, "Sections 3.0 And 4.0 of Standard Tech Specs on Limiting Conditions For Operation And Surveillance Requirements," dated June 6, 1987 (Attachment 2).

4. NRC memorandum, "Summary of Meeting Held on September 17, 1987 Relating to Generic Letter 87-09," dated October 20, 1987 (Attachment 3).

5. Inspection Manual Part 9900 Technical Guidance document, "Standard Technical Specifications (STS) Section 3.0.3 Limiting Conditions for Operation" (Attachment 4).

TSTF-529, Rev. 2 Memorandum from H. L. Thompson (NRC) to R. Starostecki (NRC), dated August 9, 1985

\\.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20151 August 9. 1985 MEMORANDUM FOR: Richard W. Starosteck1, D1M1ctor Division of Reactor Projec~. Region I FROM:

SUBJECT:

Hugh L. Thompson, Jr., Director D1v1s10n of Licensing, NRR TECHNICAL SPECIFICATION INTERPRETATION Your memor.andum dated July 15, 1985 requested an interpretation.rtth regard to the point in time th~t the time limitations of Technical Specicat10n action Mlquirements are applicable. Also, a proposed interpretation Mllated to this matter was provided for conSideration Is*an enclosure.

It is NRR's position that the time limitation of Iction requirements Ire appplicable from the point in time that it is recogni%ed that the requirements of I limiting condition of operlt1on are not met. This is as noted by your example and proposed tnterpretaion. It WlS also noted in your memo that this issue is further complicated by recent trends in NRC enforcement which cite the historical inoperability of equipment IS a factor 1n determining the Significance of loss of function violations.

In the example provided the cause for inoperlbiltty was due to.. tnt.nance that occurred prior to the time it was recognized that the component was inoperable.

We agree that in such I cale the baSis for det.rmining the safety sign1ficlnce in an enforcement action should not be limited to

'considerat1on of when it was recognized that the component was inoperable but rather on the actual total time that the requirements of the limiting condition of operation were not met. In the example you cited. the licensee should have taken appropriate measures to assure that the.. intenance was performed correctly including testing to assure that components were operable.

As I final comment with regard to the proposed interpretation enclosed to your inquiry, the Technical Specification Review Group is preparing additfonal guidance on the application of Section 3/4.0 of the Standard CONTACT:

T. Dunning, TSRG x29457

Richard W. Starostecki

.. 2 -

August 9, 1985 Technica' Specifications. This guidance will provide further clarification of time limitations related to limiting conditions of operation.nd surveillance requirements. This guidance should be available for use by Resident Inspectors and Regional personnel in the near future.

~~f~~r

~. DiviSion of Lf e"sing

TSTF-529, Rev. 2 to Generic Letter 87-09, "Sections 3.0 and 4.0 of Standard Tech Specs on Limiting Conditions For Operation And Surveillance Requirements," dated June 6, 1987

TSTF-529, Rev. 0

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UNITED~TATES NUCLEAR REGULA ORY COMMISSION WASHINGTO

D. C. 205&5 June 4, 1987 TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTS Gentlemen:

SUBJECT:

SECTIONS 3.0 AND 4.0 OF THE STANDARD TECHNICAL SPECIFICATIONS (ST5)

ON ~E APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS (Generfc Letter 87-09).

As a part of recent initiatives to improve Technical Specifications (TS). the NRC, in cooperation with the Atomic Industrial Forum (AIF', has developed a.

program for TS improvements.

One of the elements of this program ~s the implementation of short-term improvements to resolve immediate concerns that have been identified in investigations of T5 problems by both NRC and AIF.

The guidance provided in this generic letter addresses three specffic problems that have been encountered with the general requirements on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the STS.

There are five enclosures to this GeneriC letter. Enclosure 1 applies to both PWR and BWR STS and provides a complete discussion of the three problems and the staff's position on acceptable modifications of the T5 to resolve them. These modifications' should result in improved T5 for all plants and are consistent with the recommendations of NUREG-1024. -Technical Specifications --

Enhancing the Safety Impact" and the Corrmission PO'1-icy Statement on Technical Specification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 of the PWR and BWR S1S', respectively, which incorporate*'the mOdiffcations being made by this Generic Letter. Enclosures 3 and 5: (a) provfde the staff's update of the bases for the PWR and BWR STS, respectivel.y; (b) re.fleet the modifications of Sections 3.0 and 4.0 of the S1S; and (c) include fmproved bases for the unchanged requirements in these sections.

The staff concludes that these modffications will result in improved TS for all plants. licensees and applicants are encouragea to propose changes to their 1S that are consistent wfth the guidance provided fn the enclosures; however. these changes are voluntary fora" licensees and current OL applicants.

The staff would like to point out three important pOints connected with the present 1S effort. First. it is aware that the TS can be clarified, simplified. and streamlined both as a whole and with respect to the specifications that are the subject of this Generfe Letter. Nonetheless, in keeping with its short-term and purposefully narrow focus, it decided to keep these proposed modifications: (a1 focused on the three problems; (b) relatively simple; and ecl consistent with the phrasing of existing TS. Second, after the resolution of these and other identified TS problems, the staff will notify licensees and applicants of its conclusions and resulting proposals for additional short-term T5 improvements. Finally, the staff is not proposing to formally amend the STS at this time. Instead the changes will be factored into the development of the new STS anticipated as a part of the implementation of the Commission's PoliCY Statement on Technical Specification Improvements.

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The following is a sUIm1ary of the three problems covered by the enclosures.

The first problem involves unnecessary restrict10ns on mode changes by Specification 3.0.4 and inconsistent application of exceptions to it. The practical solution is to change tHis specification to define the condftions under which its requirements apply.

With respect to unnecessary mode changes.

Specification 3.0.4 unduly restricts facility operation when conformance with Action Requirements provides. an acceptable level of s3fety for continued operation.

For an LCO that has Action Requirements permitting continued operation for an unlimited period of time. entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements.

The solution also resolves the problew of inconsistent application of exceptions to SpeCification 3.0.4: (a) which' delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility.; and (b) which delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.

The second problem involves unnecessary shutdowns caused by Specification

.4.0.3 when surveillance intervals are inadvertently exceeded.

The solution is to clarify the applicabi11ty of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances. and to clarify when a missed surveillance constitutes a violation of the Operabi1ity Requirements of an LCD. It is overly conservative to assume that *systems or components -Ire inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are operable.

When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement.

Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for performing a missed surveillance before Shutdown ReqUirements apply. the TS should include a time limit that allows a delay of

. required actions to permit the performance of the missed surveillance based on consideration of plant conditions, adequate planning t availability of personnei. the time required to perform the surveiiiance, and. of course, the safety significance of the delay in completing the surveillance. The staff has concluded that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is an acceptable time limit for completing' missed surveillance when the allowable outage times of the Action Requirements are less than this, limit. or when time is needed to obtain a temporary waiver of the Surveillance Requirement.

The third problem involves two possible conflicts between Specifications 4.0.3.

and 4.0.4. The first conflict arises because Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. A conflict with this requirement exists when a mode change is required as a consequence of Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specifled surveillance interval. Specification 4.0.4 should not be used to prevent passage through or to operational modes as required to comply with jI,ct10n

. Requirements because to do so: (aj would increase the potential for a plant

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upset; and (b) would challenge safety systems. Also. certain surveil'ance(

should be allowed to be performed during a shutdown to comply with Action Requirements. Along with the modification of Specification 4.0.3 to permit a del.r of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months fn the applicability of Action Requirements.

Specificatfon 4.0.4 has been clarified to allow passage through or to.

operational modes as required to comply with Actfon Requfrements.

A second conflict could arise because. when Surveillance Requirements Cln only be completed after entry into a mode or speCified condition for which the Survefllance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed. However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore. to avoid any conflict between Specifications 4.0.3 and 4.0.4. the staff wants to make clear: (a) that it is not the intent of Specification 4.0.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to Specificatfon 4.0.4i and (b) that the delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in Specification 4.0.3 for the applicability of.

Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of allowance of any exception to Specification 4.0.4 *

. If you have any questions on this matter. please contact your project manager.

Enclosures:

As stated Sincerely,

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Frank J~~tagl ** Assocfate Dfrector for Projects Office of Nuclear Reactor Regulation

TSTF-529, Rev. 0 I

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INTRODUCTION to Generic Letter 87-09 ALTERNATIVES TO THE STS REQUIREMENTS TO RESOLVE THREE SPECIFIC PROBLEMS WITH LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS_

Generic Letter 87-09 discusses three problems regard1ng the general requirements of Sections 3.0 and 4.0 of theSTS on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements. The guidance provided in this enclosure addresses alternatives to the Standard Technical Specifications (ST5) to resolve these problems.

Problem #1 -- UNNECESSARY RESTRICTIONS ON MODE CHANGES (Specification 4.0.3)

BACKGROUND The definition of an LCO is given in 10 CFR 50.36 as the lowest functional capability or performance level of equipment requfred for safe operation of the facility~ Further, it is stated that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS unt'n the condition can be met.

Consistent with NRC's regulatory requirements for an LCO. the T5 include two baSic types of Action Requirements that are applicable when the LCO is not met. The first specifies -the remedial actions that permit continued operation of the facility not restricted by the time limits of Action Requirements. In this case, conformance to the Action Requirements~rov1des an acceptable leve' of safety for continued operation of the facility, and operation lilY proceed indefinitely as long as the remedial Action Requirements are met. The second type of Action Requirement specifies a time limit in which the LCO must be met. This time limit is the time allowed to restore an inoperable system or cOllponent to operable status or to restore parameters within specified lill1ts.

If these actions are not completed within the allowable outage time limits, action must be ta~en to shut down the facility by placing it in a mode or condition of operation in which the LCO does not apply_

Specification 3.0.4 of the STS states that entry into an operational model or other specified condition shall not be made unless the LCD is met without reliance on the provfsfons of the Action Requirements. Its intent is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits. This precludes a plant startup -

when actions are being taken to satisfy an LCO, Which -- if not completed within the time limits of the Action Requirements -~ would result in a plant shutdown to comply with the Petian ReqUirements.

lThe BWR STS use the term "operational condition" instead of the term "operational mode" that is used in PWR STS.

As used here, "operational model.

means "operational condition" for BWRs.

TSTF-529, Rev. 0 Specification 3.0.4 also precludes entering a mode or specified condition if an LeO is not met. even if the Action Requirements would permit continued operation of the facility for an unlimited period of time. Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not,apply. However, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well documented.

For example. approximately two*thfrds of the actions w~ich permit continued operation in the Westingbouse STS are exempt from Specification 3.0.4. Although the staff encourages the maintenance of all plant systems and components in an operable condition as a good practice, the T5 generally have not precluded entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operation.

o STATEMENT OF THE PROBL~

Inconsistent application of exceptions to Specification 3.0.4 impacts the operatfon (if the facility in two w~s. First. it delays startup under

.. conditions in which confonnance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility.

Second. it delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.

In this case, the LeO must be met without reliance on the Action Requirements before returning the facility to that operational mode or other specified condition for which unlimited continued operation was previously permitted in accordance with the Action Requirements.

o STAFF POSITION Jt>.

Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safe~ for continued operation. For an lCO that has Action Requirements permitting continued operati"on for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements. This is consistent with NRC's regulatory requirements for an LCO.

The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements establish a specif1ed time interval in which the LeO must be met or a shutdown of the facility would be required. However, nothing 1n this staff position should be interpreted as endorsing or encouraging a plant startup with inoperable equipment. The staff believes that good practice should dictate that the plant startup should normally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rule.

o CHANGE TO SPECIFICATION 3.D.4 The practical solution to this problem is'not the modif;cat10n of TS to note that Specification 3.0.4 does not apply, but rather a change to Specification 3.0.4 to define the conditions under which its requirements do apply.

Therefore, Specification 3.0.4 will be revised to state:

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TSTF-529, Rev. 0 Q

"Entry into an OPERATIONAL MODE or other specified condition' shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interva1. Entry into an OPEP-ATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them perm1ts continued operation of the facility for an unlimited period of time."

CHANGES TO INDIVIDUAL SPECIFICATIONS EXEMPT FROM SPECIFICATION 3.0.4 As a consequence of th~ modification described above to Specification 3.0.4, individual specifications with Action Requirements permitting continued operation no longer need to indicate that Specification 3.0.4 does not apply. They should be revised to delete the noted exception to avoid confusion about the applicability of Specification 3.0.4. However, exceptions to Specification 3.0.4 should not be deleted for individual specifications if a mode change would be precluded by Specification 3.0.4 as revised.

For example, some specifications would not satisfy the provisions under which mode changes are permitted by the revision to Specification 3.0.4 and, therefore, the exception to Specification 3.0.4 need not be deleted. It is not the staff's intent that the revision of SpeCification 3.0.4 should result in more restrictive reqUirements for individual speCifications.

Problem 12 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSING OF SUPVEIltANCE INTERVALS (Specification 4.0.3)

BACKGROUND eo Surveillance ReqUirements are defined in 10 CFR 50.36 as those r~quirements relating to test~ calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that the facility will be within the safety limits, and that the LCO will be met.

Consistent with the NRC's regulatory framework for Surveillance Requirements, Specification 4.0.3 states that the failure to perform a surveillance within the specified time interval shall constitute a failure to meet the LCO's Operability Requirements. Therefore, if a Surveillance Requirement is not met as a result of the failure to schedule the performance of the surveillance, the LCO would not be met. Consequently, the LC~'s Action Requirements must be met as when a surveillance verifies that a system or component is inoperable.

Generally, the Action Requirements include a specified time interval (i.e.,

allowable outage ti~ limit) that permits corrective action to be taken to satisfy the LCD.

When such a specified time interval ;s included in the Action Requirements, the completion of a missed surveillance within this time interval satisfies Specification 4.0.3.

o STATEMENT OF PROBLEM Some Action Requirements have allowable outage time limits of only one or two

. hours and do not establish a practical time limit for the completion of a missed

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Survei11ance Requirement. If surveillances cannot be completed within these TSTF-529, Rev. 0 time limits, a plant shutdown would usually be required.

Even if the Action Requirements include remedial measures that would pennit continued operation, they may be stated in such a way that they could prevent the perfonnance of the required surveillance. A plant shutdown would also be required if the missed surveillance applies to more than the minimum number of systems or components reouired to be operable for operation under the allowable outage time limits of the Action Requirements.

In this case, the individual specification or Specification 3.0.3 would require a shutdown.

1f a plant shutdown is required before' a missed surveillance is completed, it is likely that it would be conducted when the plant is being shut down because completion of a missed surveillance would tenninate the shutdown requirement.

This is undesirable since it increases the risk to the plant and public safety for two reasons.

First, the plant would be in a transient state involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested. This would occur when the system or component is. either out of service to allow performance of the

.surveillance test or there fs a lower level of confidence in 1ts operability because the nannal surveillance interval was exceeded., If the surveillance did

, demonstrate that the system or component was inoperable, it usually would be preferable to restore it to operable status before making a major change in plant operating' conditions. Second, a shutdown would increase the pressure on the plant staf~ to expeditiously complete the required surveillance so that the plant could be returned to power operation. This would further increase the

'potential for a plant upset when both the,shutdown and survetllance activities place a demand on the plant operators.

o STAFF POSITrON.

It is overly conservative to assume that systems or components are inoperable when,a surveillance requirement has not been performed. The oppOSite fs in fact the case; the vast majority of surveil lances demonstrate that,systems or components in fact are operable. When a surveillance is missed, it is primarily a question of operabflity that has not been verified by the performance of the required surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply. the TS should include a time limit that would allow a delay of the required actfons to permit the performance of the missed surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety Significance of the delay in COMpletion of the surveillance. After reviewing possible limits, the staff has concluded that, based on these conSiderations, ?4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this tiMP limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for ccrnpletin9 the surveillance within this period against the risks associated with the potertial for a plant upset and challenge to safety c

systems when the alternative is a shutdown to comply with Action Requirements before thp surveillance can be completed.

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, Although a missed surveillance would generally be cmpleted in less t1'me than this 24-hour limit allows, special circumstances may require additional time to ensure that the surveillance can be conducted fn a safe manner.

The time l1mfts of Action Requirements for surveillances should start when it is identified that Survefllance Requirements have not been performed. except when the Z4-hour delay fs allowed fn the fmplementation,of the Action Requfrements.

Where the 24-hour time lfmit is allowed, the time lfm1ts of the Action' Requirements are applicable either at the end of the, 24-hour limit if the

. surveillance has not been completed or at the time the surveillance is performed if the system or componeltt is found to be inoperable.

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Sever.l issues need to be clariffed regarding the additional 24-hour time limit. First, thfs limit does not waive compliance wfth Specif1catfon 4.0.3.

Under Specification 4.0.3, the faflure to perform a Surveillance Requirement wfll continue to constitute noncompliance with the Operability P.equ1rements of an LCO and to bring into play the applicable Action Requirements'.

Second, Specifications 3.0.2 and 4.0.3 should not be misinterpreted.

Specification 3.0.2 notes that a TS is being complied with w~en the Action Requirements are met within the specified time intervals. Although Specification 4.0.2 provides an allowance for extending the surveillance interval and allows for the completion of the surveillance within this time fnterval without violation of this Specification, under Specification 4.0.3 nonperformance of a Surveillance Requirement. within th, allowed surveillance 1nterval defined by Specification 4.0.2, constitutes a violation of the

,Operability Requirements of an LCO. as defined by Specification 4.0.3, and is subject to enforcement action.

To avoid any conflict among or misread1ng of Specffications 3.0.2, 4.0.3, and 4.0.2, the staff wishes to make clear (lJ that Specfficat10n 3.0.2 shall not be construed to imply, that the completion of a missed surveillance w1thfn the allowable outage time limits of the Action Requirements -- whether or not the additional 24 Mhour time limit 1s 1ncluded -- negates the vfolation of Specificat10n 4.0.3, and (2) that the failure to perform a surveillance withfn the allowable surveillance interval defined by Specification 4.0.2 constitutes a reportable event under 10 CFR 50.73(a)(2)(i}(8) because it is a condition prohibited by the plant1s TS.

Third, even though an addit10nal 24-hour time limit may apply for missed surveillances, another consideratfon is the possfbility that plant conditions may preclude the performance of the speciffed requirements. The provisfon of a 24-hour delay in the application of the Action Requirements for the completion of a missed surveillance would provide time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of current plant conditions. If a surveillance can be performed only when the plant 1s,shut down, there are only two options available to licensees when a missed surveillance is discovered durfng power operation and continued operation'is not allowed under the Action Reouirements. The first is to shut down the plant and perform the required surveillance. The other option is to seek relief from the Surveillance Requirement.

Such relief would result in the processing of a T5 amendment.

As a matter of existing policy. a temporary wafver of compliance with a TS that would unnecessarily require a shutdown or "

TSTF-529, Rev. 0 delay startup absence of some relief may be granted by NRC. A temporary waiver of compliance may be granted if the licensee has demonstrated in a e written submittal. provided before the TS LCO expired, that the facil ity can

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'safely continue to operate w,thout compliance with the TS during the time it will take to process the TS amendment,request.

o CHANGE TO SPECIFICATION 4.0.3 Specification 4.. 0.3 w111 be revised Isfollow$ to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO and to clarify the applicability of the Action Requirements and, the time during which the' limits apply:

"Fa 11 ure to perform a Surveil 1 ance Requi rement wi thi n the a 11 owed surveillance interval, defined by Specification 4.0.2. shall constitute noncompliance" with the OPERABILITY requirements for a Limiting Condition for Operation., The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the cOllPletion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

Specification 4.0.3 previously included the statement that exceptions to it are stated in individual specifications. This statement is deleted because Specification 4.0.3 is* always applicable, i.e., the impl'ed exceptions for individual specifications do not exist.

Problem 13 -- CONflICTS BETWEEN SPECIFICATtONS 4.0.3 AND 4.0.4 RELATEb To MODE CHANGES {specification 4.0.4}

There.are two parts of the general problem of conflicts between Specifications 4.0.,3 and 4.0.4 related tOlDOde changes. Each of these parts is discussed separately below.

Part 1 -- SURVEILLANCE REQUIREMENTS THAT BECOME APPLICABLE DUE TO ACTION REQUIREMENTs o

STATEMENT OF THE PROBLEM C"

Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed with1n the specified surveillance interval. First, a conflict with this TS exists when a mode change is required as a consequence of shutdown Action Requirements and when the Surve'i11ance Requirements that become applicable have not been performed within the specified surveillance interval. For instance, the plant could previously have been in a mode for which the Surveillance Requirements were not applicable and, therefore. the surveillance may not have been performed within the specified time interval. Consequently, the Action Requirements of the LCO associated with these Surveillance Requirements apply and the unit may have to be placed in a lower mode of operation than that required by the*

, original shutdown Action Requirements, or other remedial actions may have to be

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t I taken. if the surveillance cannot be completed within the time limits for these actions. This is a second problem that may be encountered.

The first problem arises because conformance with Specification 4.0.4 would requfre the performance of these. surveillances before entering a mode for whfch they apply. Source and intennediate range nuclear instrumentation and cold*

overpressure protection systems in PWRs are examples of systems for which Survef 11 ance. Requi rements may become app 1 i cab 1 e as a consequence* of 'mode.

. changes to comply with shutdown Action P.equirements.

The second problem has been mitigated by the change in Specification 4.0.3 to pe~it a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the applicability of the Action Requirements, thereby placing an appropriate time limit on the completion of Surveillance Requirements that become appl icable as a consequence of mode changes to comply w1th ~.ction Requirements.

However, the first problem can be further resolved by a change to Spec1fication 4.0.4.

o STAFF POSITION The potential for a plant upset and challenge to safety systems is heightened if*

surveillances are performed during a shutdown to comply with Action Requirements.

It is not the intent of Specificat10n 4.0.4 to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements. Accordingly.

Specification, 4.0.4 should be modified to note that its. provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. A 5i.milar provision is included in Specification 3.0.4

o CHANGE TO SPECIFICATION 4.0.4 The following will clarify Specification 4.0.4 for mode changes as a consequence of Action Requirements:

-This provision shall not prevent passage through or to OPERATIONAL ~ODES as required to comply with ACTION Requirements. a Part 2 -- SURVEILLANCE REQUIREMENTS FOR EXCEPTIONS TO SPECIFICATION 4.0.4

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STATEMENT OF THE PROBLEM An exception to Specification 4.0.4 is allowed when Surveillance Requirements can be completed only after entry into a mode or specified condition for which they apply. For example, the TS on power distribution limits are generally exempt from Specification 4.0.4. However, upon entry into the mode or specified.condition. Specification 4.0.3 may not be met because the Survei 11ance Requirements may not have been perfonned within the allowed surveillance interval. Generally, these Surveillance Requirements apply to redundant systems, and Specification 3.0.3 would apply because they are treated as inoperable under Specification 4.0.3. Therefore, allowance of an exception to Specification 4.0.4 can create a conflict with Specification 4.0.3.

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STAFF POSITION It is not the intent of Spp.cification 4.0.3 that the Action Requirements should preclude the performance of surveillances when an exception to Specification 4.0.4 is allowed.

However, since Specification 4.0.3 has been changed to permit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the appl i'cability of the Action Requirements, an appropriate time limit now exists for the completion of those Surveillance Requirements that become applicable when an exception to Specification 4.0.4 is al1owed.

TSTF-529, Rev. 0

,. to Generic Letter 87-09 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 "APPLICABILITY

[NOTE:

On,ly Specifications 3.0.4. 4.0.3, and 4.0.4 are being modified, as shown in the underlined provisions. The other speciffcations are shown for information only.)

LIMITING CONDITIONS FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to ~eet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncomplfance wfth a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as prov1ded in the associated ACTION requirements, with1n 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be inftiated to place it. as applicable, in:

a.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

b.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

c.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of fa11ure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated 1n the indiVidual specificat10ns.

This specif1cation is not applicable in. MODES 5 or 6.

PWR STS 3/4.0.. 1

TSTF-529, Rev. 0 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements sha'll be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance ReqUirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:

a.

A maximum allowable extension not to exceed 25% of the surveillance interval, but

b.

The combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.

4.0.5 Surveillance Requirements for 1nservice inspection and testing of ASME Code Class 1, 2, and 3 cOII'Iponents shall be applicable as follows:

a.

Inservice inspection of ASME Ccde Cla~s 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the AS~E Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section SO.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

b.

Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservfce inspection and testinp activities required by the ASME Boiler and PWR STS 3/4.0-2

(

TSTF-529, Rev. 0 APPLI CAB ILITY SURVEILLANCE REQUIREMENTS Pressure Vess.l Code.rid applfcable Addenda shall be applicable as follows in these Technical Specifications:

ASME Bofler and Pressure Vessel Code and applicable Addenda terminology for 1nservice inspection and testing activities Weekly Monthly Quarterly or ever" 3 months Semiannually or every 6 months Every 9 months Yearly or annually Required frequencies for performih9 inservice inspection Ind testing activities Xt ieast once per 7 days At least once per 31 days At least once per 92 days At 1 east once per 184 days At least once per 276 days At least once per 366 days

c.

The provisions of Specification 4.0.2 are applicable to the above.

requfred frequencies for performing inservfce inspection and testing activitfes.

d.

Performance of the above fnserv1ce inipection and testing activities shall be in addition to other specified Surveillance Requirements.

e.

PWR STS Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specffication.

~

3/4.0... 3

TSTF-529, Rev. 0 I to Generic Letter 87-09 s 'enc osure provides r.evised Bases for all specifications in Sections 3.0 and 4.0.J BASES Specification 3.0.1 through 3.0.4 estabHsh the, general requirements applicable to Limiting conditions for Operation. These requirements are based on the requirements for Limiting Conditions for Operation stated in the Code of '

Federal Regulations. 10 CFR 50.36(c)(2):

ftLimiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met.-

SpeCification 3.0.1 establishes the Applicability statement within each ind,vfdual specification as the requirement for when (i.e., in which OPERATIONAL MODES or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility_ The ACTION requirements establish those remedial measures that must be taken within specified time lfmfts when the requirements of a Limiting Condftfon for Operation are not met.

There are two basic types of ACTION reqUirements. ~he first specifies the remedial meaSures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for un1imited continued operation as long as the ACTION requirements '

continue to be met.

The second type of ACTION requirement specifies a time 1imit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a MODE or condition in which the specification no longer applies. It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system{s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

The specified time l1mits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or 'component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of 8 Surveillance Requirement when

. equipment is removed from service. In this case, the allowable outage time PWR STS B 3/4.0-1

TSTF-529, Rev. 0 3/4.0 APPLICABILITY BASES (Can't) limits of the ACTION requirements are, applicable when this limit expires if the surveillance has not been completed.

When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in w!1ich a new specification becomes applicable.

In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the limiting Condition for Operation are not met.

Shecification 3.0.2 establishes that noncompliance with a specification exists w en the reouirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interva1.

The purpose of this specification is to clarify that (1) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.

Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation 1s not met and the condition is not specifically addressed by the associated ACTION requirements.

(

The purpose of this specification is to delineate the time limits for placing. l.....

the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION reqUirements. It is not ~ntended to be used as an operational convenience which 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.

One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach 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 cooldown capabilities of the facility assuming only the minimum required equipment ;s OPERABLE.

This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed. the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired., thus providing an allowance for the completion of the required actions.

PWR STS B 3/4.0-2

TSTF-529, Rev. 0 I

f

~.

'II' 3/4.0 APPLICABILITY BASES (Con't)

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 plant to be in the COLD SHUTDOWN MOOE when a shutdown is required during the POWER MODE of operation. If the plant is in a lower MODE of operation when a shutdown is required. the time limit for reach-jng the next lower,.,ODE of operation ap-plies. However, if a lower MODE of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other applicable MODE. is not reduced.

For example, if HOT STANDBY is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months because the total t'jnle to reach HOT SHUTDOWN 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 POWER operation, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed.

The same principle appltes with regard to the allowable outage ttme limits of the ACTION requirements. if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less

.time than specified. the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.

The shutdown requirements of Specification 3.0.3 de not apply in MODES 5. and 6, because the ACTION reqUirements of individual specifications define the remedial measures to be taken.

Specification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher MODE of operatfon when the requirements for a limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in HODES were permitted. The ~urpose of this specification is to ensure that facility operation ;s not initiated or that higher MODES of operation are not entered when corrective actton is being taken to obtain compliance with a speCification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an accept-able level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore. in this case. entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements.

The provisions of this specification should not. however. be interpreted as endorsing thefallure to

.exercise good practice in restoring systems or components to OPERABLE status before plant startup.

PWR STS B 3/4.0-3

TSTF-529, Rev. 0 3/4.0 APPLICABILIj!

BASES (Con't)

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

Specifications 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations,,

10CFR 50.36{c)(3):

"Surveillance requirements are requ1rements relating to test. calibra-tion. or fnspection to ensure that the necessary qualfty of systems and components is maintained. that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that surveillances must be performed dur1ng the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated fn an fndividual Surveillance Requirement.

The purpose of this specf- '

f1cation is to ensure that surveillances are performed to verify the opera-tional status of systems and components and that parameters are within speci-fied limits to ensure safe operation of the facility when the piant is in a MODE or other specified condition for whfch the associated Limiting Conditions for Operation are applicatile. Surveillance Requirements do not have to be

(

performed when the facility is in an OPERATIONAL MODE for which the requirements

(,'0' of the associated Limitfng Condition for Operatio~do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a speciffcation.

Specification 4.0.2 establishes the conditions under which the specified time interval for Surveillance Requirements may be extended.

Item a. pe~its an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be, suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. Item b. limits the use of the provisions of item a. to ensure that it is not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. These provisions are SUfficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtafned from the specified surveillance interval.

Specification 4.0.3 establishes the failure to perform a Surveillance '

Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a faflure to meet the OPEPABILITY requirements for a Limiting Condition for Operation. Under the PWR STS R 3/4.0... 4

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TSTF-529, Rev. 0 I

~ I I

j j

314.0 APPLICABILITY BASE'S (Can't),

provfsions of this specification,,systems and components are assumed to be O~ERABLE when Surveillance Requirements have been satisfactorily performed withfn the specified time interval. However, nothing in thfs provision'is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement with1n the allowable outage time limits of the ACTION requ1rements restores complfance wfth the requ.irements of Specification 4.0.3. However, this does not negate the fact that the failure to have performed the survei llance within the allowed survefllance interval, defined by the provisions of Specif1cation 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that'is subject to enforcement action. Further, the failure to perform a surveillante within the provisions of Specification 4.0.2 is a violation of a Technical SpeCification requirement and 1s. therefore. a reportable event under the requirements of 10 CFR SO.73(a)(2)(i)(B) because 1t is a condition prohibited by the plant's Technical Specifications.

If the aliowable outage tilne limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown is required to comply with ACTION requirements. e.g.,

.Specif.ication 3.0.3, a 24-hour allowance is providtd to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed.

The purpOSe of thfs allowance is to 'permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance. The basfs for this allowance includes consideration for plant conditions, adequate planning. availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of MODE changes 1mposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION reqUirements are applicable at that time.

When a surveillance 1s performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requ1 rernents are applicable at the time that the, surveillance is tenninated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Requirements have to be met to demonstrate that

\\V, inoperable equipment has been restored to OPERABLE status.

PWR STS B 3/4.0-5

TSTF-529, Rev. 0 3/4.0 APPLICABILITY BASES (Can't)

Specification 4.0.4 establishes the requirement th,t all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The purpose of th1$

specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe oper~tfon of the facility. This provisfon applies to changes in OPERATIONAL ~DES or other specified conditions associated with plant shutdown as well as startup.

Under the provisions of this specification. the applfcable Surveillance Requfrements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or follOWing a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specffication 4.0.4 dO not apply because this would delay placing the facility in a lower MODE of operation.

s~ec1f1cation 4.0.5 establishes the requirement that inservice inspection of A ME Code Class 1. 2. and 3 components and ir.serv1ce testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically.updatedversion of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. These requirements apply

(,\\'~:'

except when relief has been provided in writing by the Commission

This specification includes a clarification of the frequencies for performing the 1nservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistenty in surveillance intervals throughout the.

Technical Specifications and to remove any ambiguities relative to the frequencfes for performing the required inservice inspection and testing activities.

Under the terms of this sp~cification. the more restrictive requirements of the TeChnical Specifications take precedence over the ASME Soiler and Pressure Vessel Code and applicable Addenda.

The requirements of Specification 4.0.4 to perform surveillance activities before entry into an OPERATIONAL. MODE or other specified condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps and valves to be tested up to one week after return to normal operation. The Technical Specification definition of OPERABLE does not allow a grace period before a component, that 1s not capable of performing its specified function, is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performfng its specffied function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before being declared inoperable.

PWR STS 8.3/4.0-6

TSTF-529, Rev. 0

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"'f'

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' to Generic Letter 87-09 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY

[NOTE:

Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, as shown in the underlined provisions. The other specifications are shown for information only.]

LIMITING CONDITIONS FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation,contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Lfmiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation 1s restored prior to exp1ration of the specified time intervals, complet10n of the ACTION requirements fs not required.

3.Q.3 When a Limiting Condition for Operatior. is not met, except as provided in the associated ACTION requirements, w1thin one hour action shall be inftiated to place the unit in an O~ERATIONAL CONDITION in wh1ch the Specification does not apply by placing it. as applfcable, 1n:

1., At least STARTUP within the next 6 hourS:

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . and

3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are cOlflpleted that permit operation under the ACTION requ1rements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limit1ng Condition for Operation. Excppt-io"s to these requireme"ts are stated in the indfyfdual Specifications..

This specification is not applfcable in OPERATIONAL CONDITION 4 or 5.

BWR STS 3/4.0-1

TSTF-529, Rev. 0

.~

.1 APPLICABILITY SURVEILLANCE REQUIREMFNTS 4.0.1 Surveillance Requirements shal1 be met during the OPERATIONAL CONDITIONS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed with1n the specified time interval with:

I..

A maximum allowab.1e extension not to exceed 25% of the surveillance interval, but b.The combined time interval for any 3 consecutive surveillance intervals shall not exceed 3.25 t1mes the specified surveillance interval.

I/j

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4.0.3 Failure to perform a Surveillance Requ1rement within the allowed surveillance interval. defined b, Spec1ficat;on 4.0.2. shall constitute noncompliance with the OPERABILt Y requirements for a Limiting Condition for Operation. The time limits of the ACTION reQuirements ~re applicable at the time it 15 identified that a Survefllance Re,u1rement has not been performed.

The ActIoN requirements may be delayed or up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to

¥erm1t the comx,etion of the surveillance when the allowable outaTe time im1ts of the eTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Survei lance 4..

Requ1 rements do not have to be performed on 1nope14b1e equ1 pment.

~".....

4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified. This provision shall not Rrevent passage through or to OPERATIONAL CONDITIONS as required to comp 1 y wit ACTION requ i rements

4.0.5 Surveillance Requirements for inserv1ce inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a.

Inservice inspection of ASHE Code elas.s 1. 2, and 3 components and 1nservice testing of ASHE Code Class 1, 2. and 3 pumps and valves shall be performed in accordance with Section XI of the ASHE Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(9)(6)(1,.

b.

Surveillance intervals specified in Section XI of the ASHE Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASHE Boiler and BWR STS 3/4.0-2

TSTF-529, Rev. 0

~.

4' t{. "

APPLI CABILITY SURVEILLANCE REQUIREMENTS Pressure Vessel Code and applicable Addenda shall follows 1n these Tec~nical Specificat10ns:

be app11cable as ASHE Boiler and Pressur! Vessel Required frequenc1es Code and applicable Addenda for performing inservice terMinology for inservice inspection and testing inse!ction and testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months Every 9 IIOnths At. least once per 184 days At least once per 216 days Yearly or annually At least once per 366 days

c.

The provfsions of Specification 4.0.2 are applicable to the above required frequencies for performing inserv1ce inspection and testing activitfes.

d.

Performance of the above inservice inspection andtestfng activities shall be in addition to other spec1fied Surveillance Requirements.

e..

Nothing in the ASHE Bofler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specification.

~

BWR STS 3/4.0-3

TSTF-529, Rev. 0

(:0'

. to Generic Letter 87-09 3/4 LIMITING CONDITIONS FOR OPE'RATION AND SliRVEILLANCE' PFgUIREMENTS 3/4.0 ApPLICABILITY

[NOTE: This enclosure provides revised Bases for all speCifications in Sections 3.0 and 4.0.J BASES Specifications 3.0.1 through 3.0.4 establish the general requirements applicable to limiting Conditions for Operation. These requirements are based on the requirements for L1mitin~ Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):

"Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the conditfon can be met.n.

Specification 3.0.1 establishes the Applicability statement within each individual specification as the requirement for when (f.e., in which OPERATIONAL CONDITIONS or other specif1ed conditions) confo'rmance to the Limiting Conditions for Operation is requ;red for safe operation of the facility. The ACTION requ1rements establish those remedial measures that must be taken within specif1ed time limits when the requirements of a Limiting Condition for Operation are not met. It is not intended that the shutdown ACTION requirements he used IS an operational convenience which pennits (routine) voluntary removal of a system(s) or component(s).from servfce in lieu of other alternatives that would not result in redundant systems or components being fnoperable.

There are two basic types of ACTION requirements.

The first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In th1s case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements c~r.t1nue to be met.

The second type of ACTION requirement specifies a time limit in which confonnance to the conditions. of the Limiting Condition for Operation must be met.

Th1s time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in an OPERATIONAL CONDITION or other specif1ed condition in which the specification no longer applies.

The specified time limits of the ACTION requirements are app1ic~b1e from the point in time it is identified that a Limiting C~ndition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems.

Indiv1dual specifications may include a specified time limit for the completion of a Surveillance Requirement when BWR STS B 3/4.0-1

TSTF-529, Rev. 2 NRC Memorandum, "Summary of Meeting Held on September 17, 1987 Relating to Generic Letter 87-09," dated October 20, 1987

TSTF-529, Rev. 0 TSTF-529, Rev. 0

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UNITiOrr.a.ru NUCLEAR REGULATORY COMMISSION W~'NGTON. D. c.....

OCT! 0 T9S7 OOCY.ET NOS:

50*325/324 & 50-400 LICENSEE:

CArolina Power ~ Light Company FACILITY:

Shearon Harris, Unit 1

SUBJECT:

SUMMARY

OF MEETING HELD ON S£PT£MS£R 17. 1ge1 RELATING TO GENERIC LETTER 87-09 A metting was held with representAtiYes of the Caro11na Power & Light Com~any (C~&L) in Bethesda. MO. on Septem~er 11, 1981 to discuss Generic Letter a7*0~.

Sections 3.0 and 4.0 of the Standard Techn1ca1 Specifications (STS) on the applicability of Limiting Conditions for Operation and Surveillance Requirtments" dated June 4, 1987. as it relates to the Shearon Harris Unit 1 And the Srunswick Units 1 & 2 nuclear power plants. A list of attendees 1s 4ttachtd.

CP~L expressed concern about the potential for m1sinterpretation of the sentence underlined below, for ease of reference. and which l~pears on ~age a 3/4.0-1 of Inclosure 3 to Generic ~!tter 87.09.

Th. concern expressed fs that it could prohibit CPlL from gOing voluntarily into I Limiting Condition for Operaticn (LeO) 1n clrtain Just1ff&ble instances.

An txampie of such an instanct would bt if * ~11 1eak developed in a pu~ SI,l whieh in itself would not rendlr the p~ inoperable but had the potlnt1., for rlndering the pump inoperable at a future date.

CP&L would likl the option of voluntarily entering I LeO by isolating the p~ and making tne required re~lfr1 w1thout being cited for such action. The HRC sta1f noted that the underlined stCtion of the Sases for Specification 3.0.1. noted above. would not &~~ly to the exampl. cited by CP&L since it is not I casl in whicn redundant s1stens would be out of sirvici. The staff noted that in addition to the two basic types 01 action requirements that art noted in the,second paragraQh of the Sases for S~ec1fication 3.0.1. a third type would define time limits for directly placing the plant in a shutdown condition. It was neted that the sentence in question, underlined abave. that was a,concern to CPIL was intended to apply to this ty~e of snutdown action requirement.

The staff noted that a Similar sintenci is includld in the Bases for Specification 3.0.3.

In bath cases the point of clarification is that the last echelon of defense should not be removed f~ service such that this would invoke a prompt shutdown,action requirement. in i,1eu of other alterna-tives that would not rtsult in redundant systems being out of servici simultaneously.

TSTF-529, Rev. 0

.. 'I.

Cfl~L LI!lkp.d f('lr D c1a.'iflcaUon of whln (I milled sllrv~111onc:1' is "tpol'led untlur the LElt I.lll r,

H"f !t(\\rr stalud that If l\\ rn1$ud lurvelllancp is not p~rfo'~Qd within the l1Clw1Incr. fnr ('~t(!nd1no til(' 5urvl"llhnt~ 1 nlfH'VII 1,H IH'{wiclt'c1 hy 5per.\\f1~etl{Jn 4,(\\.~, It ~/~\\'ld he n~portoblr.

T"I-. 15 ct'nsistont with tho clnl'ifieallon of the LER Rlih thal I! p,'ovlcJccJ III NUREG-lOrZ. SuppleOif.mt 11.

CfJ&L aakod I r thOI'A WcH nlly si~n I fltM1CP hp.twHefl lhe words tlflI11ul'e to "'t,lll

,\\lid the wo,'d!l IInonr.onlp11"nce with" \\'Ihlch is C'II I','enl'y In Spnciflcatlo'1 4.0.3 or G(lIl(1r1r h" tar U7.. 09.

Tho ~tl\\rr !-l&lted they hot.h mt!lln th.! SllRlG 41H.I thol It dO(,!1 110 t. lmposl" lillY /lOW I'~qu I,'ement,

cc: See nox t paoo III ~ii~ll\\lJT lOt-;:

S(lr,\\lld( hi'll 1 I~t rt~!: PI';I ;\\~~

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TSTF-529, Rev. 2 Inspection Manual Part 9900 Technical Guidance document, "Standard Technical Specifications (STS) Section 3.0.3 Limiting Conditions for Operation"

TSTF-529, Rev. 0

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UNITeO sr AT'ES NUCLEAA RIGULATOAY COMMISSfON W.$HtHGTON. o. e. 20IIf NRC INSPECTION MANUAL

!LB6 PART 99CO: TECHNICAL GUIUAHC!

STANDARD TECHNICAL SPEC!FlCATICHS STS SECTION 3.0.3 LIMITING CONOITIO~ FOR OPERATION I,

A.

PURPOSE To provide guidance en -Standard rlc:nnic:ai Specific:ations (STSLSectiOff 3.0.3 t

as it r,l,tes to limiting eond~t1cns for OPfrlt1,on (loCO).

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s.

BACICG~OUHD

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Reg,ions II I and V hive reported the incorrect us. 0' the pM2'41s10ns of STS Sect;on 3.0.3 by 1icensees.

As an ex,mp1." Technic., Specific.tion 3.1.A.5.b

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for, O.,.esden anc Qu.d Cities, and simnar $~~if'1catio"s for other ~1ants..

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estab11sh.the c:on'tainment ox)'gen eonc.ntra~ion r'Quirement$ eluring' the,4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months pr10r to a shutdown, i'nc1 attar the N'etor moat switch has betn placefi

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in the ryn position on startup. If the oxygen-,"owab1. ~onc.ntr.t1on excle~s.

the tlchn1ea' spec1f1clt1o~ limit for mort than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to shutdown O~

fOr more thAn 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the reactor mode,.witch has been p11ctd in the i rJn position on startup, the p1ant is in v1ulat1on of the ~'O Ind should be

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.shut dewn 1 n accordanc! with the Lea.

However, the, ican... proposed to

!"4 tnter LeO 3.0.3 at the end of the Z4-hour per10d.nd usa tnt rtqu1remt~ts of Leo 3.0.3 to nava an addition.' '2 hour1 to shut down the p1ant.

Technical Spec:1f1c;at1on J. 7.A.S.b, oefinesthe two conditions fa.. which oxygen eoncen-r tra:1on C.1n be exceeded. FOr eith.r condition, an txp11cit Z4-hour time limit for $hutting down is pro4/1ded.

There Ire no ather c1rcumst.nclS which ar.

not accounted for, Inc STS 3.0.3 does not app'Y.

Tn. basic 1nfoMltat1on p,"ov1d.d tc.R... 1ons I'! I Ind V ~o"cern1ng the us. 01 STS 3.0.3 is diseu.,.d in the s.ct10n below.

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a. " 1

c.

DISCUSSION i

I.CO 1$ defined in STS 3.0.3 is not intended to be used IS an optrlt1onal CQn~.ni.nce Which permi~s redundant s,1ety systems to be out of serviCt for a i limited period of t1me.

Its intended pu."ose 11 to provide guidance on the

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time limits for In *c~."ly" shutdown when the 'nci1vidual LCD or ACTION J~.

stat.ments in other sflee1f1clt1ons cannot tM ~1ieC with.

Voluntary tntry into LeO 3.0.3 d.1 1berat.ly r1lmOves 'lne l.st litte 0" d.f*,,5e.ga1nst potentially harmful events.

Doing so allows removal of I system fram ser~1c.

when the redund.nt system is.1rtldy 1n~~.rlble. An,'ct1on Hlh th~S weld u~ !!

snow a disrl9ard for plant safety and,s unac=eptab..

it a so SIIOU ~ ~ 1"*

emphasfztd tijat removal of a sy,tam from service is,just1fied only for

~e$t. ma1ntlnence, or repair purposes.

Issue Date: oa/31/87

TSTF-529, Rev. 2 Model Application for Adoption of TSTF-529

TSTF-529, Rev. 2 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

PLANT NAME DOCKET NO.

50-[xxx]

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-529, "CLARIFY USE AND APPLICATION RULES"

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

The proposed amendment would modify TS requirements in Section 1.3 and Section 3.0 regarding LCO usage, and the TS Bases for Section 3.0 regarding Limiting Condition for Operation (LCO) usage 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." The availability of this TS improvement was announced in the Federal Register on [Date] ([ ] FR [ ]) as part of the consolidated line item improvement process (CLIIP). provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. provides revised (clean) TS pages. provides existing TS Bases pages marked to show the proposed changes.

Approval of the proposed amendment is requested by [date]. Once approved, the amendment shall be implemented within [ ] days.

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

TSTF-529, Rev. 2 Page 2

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct. Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Attachments:

1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-Up)

3. Revised Technical Specifications Pages

4. Proposed Technical Specifications Bases Changes (Mark-Up)

[The model application does not include these attachments, which will be added by the licensee.]

cc: NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-529, Rev. 2 Page 3 ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) and the TS Bases for Section 3.0, "LCO Applicability" and "SR Applicability," to clarify the use and application of the TS usage rules, as described below:

Section 1.3 is modified to clarify "discovery."

Revisions are made to Section 1.3 to discuss exceptions to starting the Completion Time at Condition entry.

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. The LCO 3.0.4.a Bases are revised to support the clarification.

LCO 3.0.4.a Bases are modified to clarify that Required Actions must be followed after entry into the Modes and other specified conditions in the Applicability. An example is added to the Bases.

The LCO 3.0.5 Bases are revised to clarify its application.

The Bases of SR 3.0.2 and SR 3.0.3 are revised to remove the term "Operational Convenience."

Changes are made to the Bases of LCO 3.0.3 and SR 3.0.3 to use consistent terminology.

The LCO 3.0.3 Bases are corrected to state that a unit shutdown may be terminated and LCO 3.0.3 exited if the LCO is no longer applicable.

The LCO 3.0.4.c Bases are modified to replace a misleading TS reference.

The LCO 3.0.5 Bases are modified to clarify that LCO 3.0.5 should not be used if there are other alternatives to demonstrate that an LCO is met and maintain compliance with Actions. The LCO 3.0.5 Bases examples are revised.

The SR 3.0.3 Bases are modified to clarify when SR 3.0.3 may be applied and to state expectations for applying SR 3.0.3 when an SR has not been performed for an extended period.

[LICENSEE] requests NRC review and approval of the changes to the TS Bases. The proposed changes to the LCO 3.0 and SR 3.0 Bases have the potential to alter the application of the TS. In accordance with Paragraphs b.1 and d of the TS Bases Control Program, the proposed Bases changes must be reviewed and approved by the NRC prior

TSTF-529, Rev. 2 Page 4 to implementation. Following approval of the license amendment request, [LICENSEE]

will issue the revised Bases pages in accordance with the TS Bases Control Program.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation

[LICENSEE] has reviewed the model safety evaluation dated [DATE] as part of the Federal Register Notice of Availability. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-529. [As described in the subsequent paragraphs, ][LICENSEE] has concluded that the justifications presented in the TSTF-529 proposal and the model safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

2.2 Optional Changes and Variations

[LICENSEE is not proposing any variations or deviations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staffs model safety evaluation dated

[DATE].] [LICENSEE is proposing the following variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staffs model safety evaluation dated [DATE].]

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

Omission of one or more changes proposed in TSTF-529 is an acceptable variation from the Traveler.

[The [PLANT] TS utilize different [numbering][and][titles] than the Standard TS on which TSTF-529 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-529 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-529 to the

[PLANT] TS.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination

[LICENSEE] requests adoption of TSTF-529, "Clarify Use and Application Rules,"

which is an approved change to the standard technical specifications (STS), into the

[PLANT NAME, UNIT NOS] technical specifications (TS).

[LICENSEE] 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:

TSTF-529, Rev. 2 Page 5

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

Response: No.

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the TS and the TS Bases for Section 3.0, "LCO Applicability" and "SR Applicability," to clarify the use and application of the TS usage 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. The Bases of LCO 3.0.4.a are modified to clarify that Required Actions must be followed after entry into the Modes and other specified conditions in the Applicability. The SR 3.0.2 and SR 3.0.3 Bases are revised to remove the term "operational convenience," and the LCO 3.0.3 and SR 3.0.3 Bases are revised to use terminology consistent with the corresponding TS. The LCO 3.0.5 Bases are modified to clarify its applicability to all TS Section 3 Required Actions, and that LCO 3.0.5 should not be used if there are other alternatives to demonstrate Operability that maintain compliance with Actions. An inaccurate example in the LCO 3.0.5 Bases is replaced and another example is revised. The SR 3.0.3 Bases are modified to clarify when SR 3.0.3 may be applied and to state expectations for applying SR 3.0.3 when an SR has not been performed for an extended period.

The changes to Section 1.3 and 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 Bases changes clarify the appropriate application of the existing TS requirements. Since the proposed change does 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.

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. The proposed change clarifies the current application of the specifications.

The clarification of "discovery" in Section 1.3 does not change the current timing or actions to be taken when LCOs are not met. The changes to the TS Bases clarify the application of the existing requirements.

TSTF-529, Rev. 2 Page 6 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 Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. As a result, plant safety is either improved or unaffected. The proposed changes to the Bases clarify the application of the existing TS requirements and, as a result, have no significant effect on a margin of safety.

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

Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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.

TSTF-529, Rev. 2 Improved Technical Specifications Mark-Up

Completion Times 1.3 Babcock & Wilcox STS 1.3-1 Rev. 4.0 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 declaration 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 which 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 B.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.

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 TSTF-529, Rev. 2

Completion Times 1.3 Babcock & Wilcox STS 1.3-2 Rev. 4.0 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 Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

TSTF-14-02, Transmittal of TSTF-529, Revision 2, Clarify Use and Application Rules

Text

SUBJECT:

Description:

Description:

Description:

SUBJECT:

SUBJECT:

Enclosures:

SUBJECT:

SUMMARY

SUBJECT:

Dear Sir or Madam:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

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