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Technical Specifications Task Force - Transmittal of TSTF-529, Revision 3, Clarify Use and Application Rules.
	ML15259A337
Person / Time
Site:	Technical Specifications Task Force
Issue date:	09/14/2015
From:	Clark J, Gustafson O, Hegrat H, Morris J; B & W Nuclear Operations Group, BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-15-08
	Download: ML15259A337 (160)
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TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY September 14, 2015 TSTF-15-08 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-529, Revision 3, "Clarify Use and Application Rules" Enclosed for NRC review is Revision 3 of TSTF-529, "Clarify Use and Application Rules."

TSTF-529 is applicable to all plant types. It was revised based on discussions with the NRC staff.

The TSTF requests that the NRC continue to bill the Boiling Water Reactor Owners' Group and the Pressurized Water Reactor Owners Group for the review of TSTF-529.

Should you have any questions, please contact us.

James R. Morris (PWROG/W) Joseph A. Clark (BWROG)

Otto W. Gustafson (PWROG/CE) Henry L. Hegrat (PWROG/B&W)

Enclosure cc: Michelle Honcharik, Licensing Processes Branch, NRC Robert Elliott, Technical Specifications Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

BWROG-121, Rev. 0 TSTF-529, Rev. 3 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler Clarify Use and Application Rules NUREGs Affected: 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 Revision Proposed by: TSTF Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 27-May-10 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 17-Jun-11 TSTF Review Information TSTF Received Date: 25-Aug-11 Date Distributed for Review 25-Aug-11 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 21-Sep-11 NRC Review Information NRC Received Date: 21-Sep-11 NRC Comments:

See the Revision 1 description.

Final Resolution: NRC Requests Changes: TSTF Will Revise Final Resolution Date: 16-Oct-12 TSTF Revision 1 Revision Status: Closed Revision Proposed by: TSTF 14-Sep-15 Copyright(C) 2015, 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.

BWROG-121, Rev. 0 TSTF-529, Rev. 3 TSTF Revision 1 Revision Status: Closed Revision

Description:

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.

14-Sep-15 Copyright(C) 2015, 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.

BWROG-121, Rev. 0 TSTF-529, Rev. 3 TSTF Revision 1 Revision Status: Closed Owners Group Review Information Date Originated by OG: 24-Jan-13 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 13-Feb-13 TSTF Review Information TSTF Received Date: 13-Feb-13 Date Distributed for Review 13-Feb-13 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 28-Feb-13 NRC Review Information NRC Received Date: 28-Feb-13 NRC Comments:

NRC accepted for review on 6/20/2013.

Final Resolution: NRC Requests Changes: TSTF Will Revise Final Resolution Date: 18-Jul-13 TSTF Revision 2 Revision Status: Closed Revision Proposed by: NRC Revision

Description:

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.

14-Sep-15 Copyright(C) 2015, 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.

BWROG-121, Rev. 0 TSTF-529, Rev. 3 TSTF Revision 2 Revision Status: Closed 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)

Owners Group Resolution: Approved Date: 16-Sep-13 TSTF Review Information TSTF Received Date: 16-Sep-13 Date Distributed for Review 18-Sep-13 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 18-Nov-13 NRC Review Information NRC Received Date: 14-Jan-14 NRC Comments:

See the Revision 3 description.

Final Resolution: NRC Requests Changes: TSTF Will Revise TSTF Revision 3 Revision Status: Active Revision Proposed by: TSTF Revision

Description:

At the February 5, 2015 TSTF/NRC meeting, the NRC discussed new RAIs on TSTF-529. On a June 2, 2015 NRC/TSTF teleconference, the TSTF agreed to revise TSTF-529 in lieu of NRC sending a formal RAI.

TSTF provided a draft revision for NRC comment on June 30, 2015. At the July 23, 2015 TSTF/NRC public meeting, the NRC provided comments on the proposed change.

The following changes are made to TSTF-529 in Revision 3:

1. Section 1.3 is revised to state, "Unless otherwise specified, the Completion Time begins when a senior 14-Sep-15 Copyright(C) 2015, 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.

BWROG-121, Rev. 0 TSTF-529, Rev. 3 TSTF Revision 3 Revision Status: Active licensed operator on the operating shift crew with responsibility for plant operations makes the determination (instead of "declaration") that an LCO is not met." The term "declaration" implied a process (the operability determination process), which is not what was intended.

2. In the LCO 3.0.5 Bases, reference was made to an NRC letter to Calvert Cliffs nuclear power plant. That reference is removed from the Bases but remains in the justification.

3. A change to SR 3.0.3 is made. The sentence "The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed" is added and the Bases are revised to describe determining a "reasonable expectation" when a Surveillance has not been performed before or has not been performed for a long period.

4. The justification and model application were revised to no longer request NRC approval of the Bases changes.

5. The justification was revised to reorder and improve the discussion.

Owners Group Review Information Date Originated by OG: 04-Aug-15 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 26-Aug-15 TSTF Review Information TSTF Received Date: 31-Aug-15 Date Distributed for Review 31-Aug-15 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 14-Sep-15 NRC Review Information NRC Received Date: 14-Sep-15 Affected Technical Specifications 1.3 Completion Times LCO 3.0.2 Bases LCO Applicability SR 3.0.2 Bases LCO Applicability 14-Sep-15 Copyright(C) 2015, 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.

BWROG-121, Rev. 0 TSTF-529, Rev. 3 LCO 3.0.3 Bases LCO Applicability SR 3.0.3 LCO Applicability SR 3.0.3 Bases LCO Applicability LCO 3.0.4 LCO Applicability LCO 3.0.4 Bases LCO Applicability LCO 3.0.5 Bases LCO Applicability 14-Sep-15 Copyright(C) 2015, 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. 3 1.0 Description The proposed change will revise sections 1.3, "Completion Times," and sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications (TS), and the TS Bases for Section 3.0, "LCO Applicability" and "SR Applicability." The proposed changes clarify and expand the use and application of the TS usage rules. The proposed change addresses 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 revised to clarify "discovery."

2. Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

3. Limiting Condition for Operation (LCO) 3.0.4.b is revised 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 this clarification.

4. Surveillance Requirement (SR) 3.0.3 and the associated Bases are revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.

5. The LCO 3.0.4.a Bases are revised 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.

6. The LCO 3.0.5 Bases are revised to clarify its application.

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

8. The LCO 3.0.3 and SR 3.0.3 Bases are revised 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 revised to replace a misleading TS reference.

11. The LCO 3.0.5 Bases are revised 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.

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TSTF-529, Rev. 3 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 proposed change includes changes to the TS Bases. The regulation at Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36, states: "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." A licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the Technical Specifications Bases Control Program. The proposed TS Bases changes are consistent with existing TS and the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).

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 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.

4.0 Technical Analysis 4.1 Section 1.3 is revised 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."

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 under 10 CFR 50.72 and 10 CFR 50.73. Except in Section 1.3, the TS use the term "discovery," but Section 1.3 Page 2

TSTF-529, Rev. 3 uses the phrase "time of discovery." This creates confusion because the reportability regulations 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 determination 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.)

This position is 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.

In the proposed change, the phrase "and an ACTIONS Condition is entered" is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into the Conditions. In those circumstances, a Completion Time does not begin.

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 Page 3

TSTF-529, Rev. 3 responsibility for plant operations determines that an LCO is not met and a Condition is entered.

4.2 Section 1.3 to revised 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 that 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 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.

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TSTF-529, Rev. 3

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

The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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:

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TSTF-529, Rev. 3 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 LCO 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options 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 Page 6

TSTF-529, Rev. 3 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).

4.4 SR 3.0.3 and the associated Bases are revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3 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 met1 during the Modes or other specified conditions in the Applicability. This is a key consideration in the application of SR 3.0.3.

In December 2008, the NRC issued a response to Task Interface Agreement (TIA) 2008-004, "Evaluation of Application of Technical Specification (TS) 4.0.3, 'Surveillance Requirement Applicability,' At Pilgrim" (NRC ADAMS Accession No. ML083660174).

The Pilgrim TS 4.0.3 is similar to STS SR 3.0.3. In the TIA response, the NRC took the position that a missed SR is different than an SR that was never performed, and that SR 3.0.3 is not applicable to SRs that have never been performed.

Information is added to SR 3.0.3 and the SR 3.0.3 Bases to address the NRC's position on the application of SR 3.0.3 and to allow SR 3.0.3 to be applied, when appropriate, to missed Surveillances that have never been performed. SR 3.0.3 is revised to state:

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

1 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."

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TSTF-529, Rev. 3 The SR 3.0.3 Bases are revised to discuss the SR 3.0.3 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 concept of "reasonable expectation" is discussed in NRC Inspection Manual Chapter 0326, Section 3.9, that 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.

The standard of "reasonable expectation" is also appropriate for the question of whether a licensee may apply SR 3.0.3 to an SR that has not been performed within its specified Frequency. In both cases the question to be addressed is whether the associated Page 8

TSTF-529, Rev. 3 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 that 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.

The proposed change to SR 3.0.3 is 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 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 SR 3.0.3 Bases discuss determining whether there is a reasonable expectation that the SR will be met when performed. In particular, the Bases discuss the case of an SR that has never been performed or has not been performed for a long time, such that establishing a reasonable expectation that the SR is met is more difficult. The proposed change to SR 3.0.3 and the discussion in the SR 3.0.3 Bases address the NRC's position by providing guidance to licensees on application of SR 3.0.3 in such circumstances.

4.5 LCO 3.0.4.a Bases are revised to clarify that Required Actions must be followed after entry into the Modes and other specified conditions in the Applicability 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 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:

Page 9

TSTF-529, Rev. 3 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.

4.6 LCO 3.0.5 Bases are revised 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.

Page 10

TSTF-529, Rev. 3 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 that is to be returned to service.

This addresses the majority of situations; however, it does not address all situations in that 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. It is not clear that the Required Action to close the block valve falls under the LCO 3.0.5 allowance.

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. (emphasis added)

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

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

Page 11

TSTF-529, Rev. 3 4.7 SR 3.0.2 and SR 3.0.3 Bases are revised 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 missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should... (Emphasis added).

Page 12

TSTF-529, Rev. 3 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 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 Page 13

TSTF-529, Rev. 3 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 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 LCO 3.0.3 and SR 3.0.3 Bases are revised to use consistent 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.

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.

Page 14

TSTF-529, Rev. 3 4.9 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 3.0.3 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 that 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 LCO 3.0.4.c Bases are revised to replace 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 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 do not 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)."

Page 15

TSTF-529, Rev. 3 4.11 LCO 3.0.5 Bases are revised 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 Many specifications contain provisions that 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 that allows entry and exit to perform repairs, and the containment isolation valve specification contains an Actions Note that 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.

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.

Page 16

TSTF-529, Rev. 3 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 that 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 NUREG-1431 (Westinghouse plants) contains Required Actions Notes that allow channel testing in lieu of using LCO 3.0.5.

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

5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration Analysis The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. 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. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

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 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 change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes does not significantly affect system Operability, the proposed change will have no significant effect on the initiating Page 17

TSTF-529, Rev. 3 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.

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. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed is there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

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

Based on the above, 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.

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.

Page 18

TSTF-529, Rev. 3 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, Chapter 0326, "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).

Page 19

TSTF-529, Rev. 3 Attachment 1 Memorandum from H. L. Thompson (NRC) to R. Starostecki (NRC), dated August 9, 1985

TSTF-529, Rev. 3 UNITED STATES NUCLEAR REGULATORY COMMISSION llUSHINGTOH, D. C. 2Cllll August 9. 1985 MEMORANDUM FOR: Rfchal"d W. Starostect1, D1Nctor Divtston of Reactor Projec~. R1gtan I FROM: Hugh L. Thampson, Jr., Director Division of Licensing, NRR

SUBJECT:

TECHNICAL SPECIFICATION INTERPRETATION Your maonndum dated .July 15, 1985 requested an 1nterpretatton with regar'd to the point in time thl.t the time 11mftat1ons of Techn1ca1 Spec1cat1on action requirements are applicable. Also, a proposed interpretation related to this 111ttar was provided for consideration as* an enclosure.

It fs NRR's posftfon that the ti* limitation of action requfr1Mnts

'" appp1icab1e frm the point tn ti* that ft 1s recogntiad that the

raquf 1'1118nts of a 11111ttng condttfon of operatton IMt not *t. This is as noted by your U111Pl* and proposed interpreta1on. It was also noted in your llllllO that this issue is further complicated by rec:1nt trends f n NRC enforc1111ent which cite the historical tnoperabtlity of equipment as a factor tn determining the s1gn1ffcance af loss of function violations.

In th* example provided the cause for inoperabi11ty was due to maintenance that occuM"ed prior to the t i

it was recognized that the camponent was inoperable. We ,,,.. that in such 1 case the basis for determining the safety significance in an enfol"CWftt action should not be lflllted to

consfde.,..t1on of when ft was recognized that the component was inoperable but rath*r on the actual total tf111e that the requirements of the limiting condition of operation were not met. In the ex1111Ple you cited, the licensee should have taken appropriate measures to assure that the *1ntenance was performd carrectl.Y f ncludtng usttnv to assure that ccmponents were operable.

As a final cannent with Ng1rd to the proposed interpretation enclosed to your inquiry, the Technical Specification Review*&roup is preparing additional guidance on the application af Section 3/4.0 of the Standard CONTACT:

T. Dunning, TSRG x29457

TSTF-529, Rev. 3

Richard W. Starosteck1 August 9, 1985 Technical Specif1c1tfons. This guidance will provide further clarif1catian of tf111 1imftat1ons related to lfmftfng conditions of operatfon .nd survef11ance requfrements. This guidance should be available for use by Resident Inspectors and Regional personnel in the near future.

TSTF-529, Rev. 3 Attachment 2 Enclosure 3 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. 3 dune 4, 1987 TO A1.L LIGHT WATER REACTOR LICE1tSE£S MD APPt.tCANTS Gentl-:

SU&J£CT: um* 3.0 MD 4.0 OF THE STMOARO TECHNICAL SPECIFICATIONS (STS) 01 1'N! APPUCABlUTY OF UMmM CONDITIONS FOR OPERATION AND SURVEll.LMCE R£0UIRSEIT'S (&enerfc Letter 87-ot)

As a part of recMt 1aft'latfves ta fWIPt'OVe Ttchnfc11 Specfffcatfons (TS), the NRC, fn cooperation with the At*fc Industrial Fon. (AIF). has developed a progrua for TS fmprovanents. OM of the el-nts of this p1"0gr111 .1s the f fmp11111entation of sttm*tenn fmproW1111Mts to resolve fmedfate concerns tbat

hive been identfft1d fa favest1tat1ons of TS probl* by both NRC and AIF.

J that hive been ~ntel"ed wfth the..,_...,

The tvfdam:e provided in tllis 'generic letter address.s thl"ee spec1ffc Pf"Oblem requfr11111nts on the 1pp11cab111ty ,

of Lfn1fttng Cond1t1ons for Operation (LCO) and Survef11attce Requiraents fn .

1

$ect1ons 3.0 Ind 4.0 of the STS*

1 There are five enclosures to tttfs Gntrtc Letter. Enclosure 1 applies to both Nl llKt BVlt !TS and provides a ~lete dfscvssfon of the thl"ff pl"ObllllS and the staff1 s p0sitfon on 1cc*tal>le ilodfffcat1ons of the TS ta resolve

them.. Tiies* mcHff cattons* shauld result in flllPl"OYed TS for an plants and are conststent with the rec_.d1tions of IUREG-1024. *Technical Spec1f1cat1on .....

Enttancfng tile Safety l"PICt* and the eo.tssfon Poticy Stltment on Technical SpecificattOl'I lJnpr"OYalents.. bcl0$VNI 2 and 4 provide Sections 3.0 and 4.0 of the P11R and IVR STS*. raspectfve1y, wttfeh fncorporate .. tbe llOdfffcattons befng

de by thfs Serterfc Letter. Enclosures 3 and 5: (a) provfde the staff's update of the HHS for the Nt 1nd 8ilR STS, respectfvel1; {b) reflect the modi ftc*t1ons of Sections l.O and 4.0 of tlte STS; and ( c} 1nclucfe fmproved bases for the unchanged requ1reents in these sections.

ne stiff conc1u4ts that these _.ftcatfons wtl 1 result in improved TS for all plants. lfcusees and applicants are ettCOl.tt"4teci to f.Jt"Opose changes to thef r TS that are consistent wfth the guidance pl"OV1cfed fn the enclosures; h0wv11". these changes are voluntary for.all lfcensees and cu.-rent ot applicants ..

The staff wovld lf ke to potnt oat thNI tMPOrtant po1..U connected wfth tfle present TS effort. ffrst. ft 1S aware that the TS can be clarified, Sfft1P1fffed. and strealined lath as a whole and with respect to the specfffcat10ftt that are the std>3ect of thfs Generic L*tter. Nonetheless, 1n keeping with fts short-tem and purposefully narrow focus. 1t decided to keep these proposed lll>Cf1fieations: (aJ focused on the three problan; (b) relatively simpl*; amt (c1 conststent with the phrasing of existing TS.. Second. after the resolutfon Of these and other identified TS proJ>tBS, the staff wfll notff.Y lfcansees and applicants of its conclusfons and resultfnf proposals for l additional sllort-tetm JS 1rapn>Y8Plents. Ffnen.r. the staff is not proposing to fonna1Ty emerid the STS at thfs tf*. Instead the changes will be. factored fnto the developnent.of the new STS anticipated as a part of the i11Plernentatton of the Ct11111sstonts P'°l1cy Statement ,on Technical Spec1ffcatfon lmproYements.

8706090039

TSTF-529, Rev. 3

~

The following ts a SUR!lry of the three problems covered by the enclosures The ffrst problem 1nvo1ves unnecessary restrictions on mode changes by

Specification 3.. 0.4 and fncons1stent application of exceptions to ft. The practical solution ts to change tHis specfffcation to define the condftfons under whfch its requirements apply. Wfth respect to unnecessary mode changes.

Specfficatfon 3.0.4 undu13' restricts fadl ft)' operation when confonnance with Action Requf raents provides,, an acceptable 1eve1 of safety for continued operatfon. For an LCO that has Aetfon Requirements permitting continued operation for an unlimited period of time. entry into an opet'"ation mode or other specified condf tfcm of operation should be permitted f n accordance with th* Action ftequirements. The solution also resolves tha problart of inconsistent application of exceptions to Specification 3.0.4: (a) which' delays startup under conditfons in which confon111nce 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 tfhen the facility is required to bt fn a lower mode of operation H a consequence of other Action Requirenents.

The second problem involves unnecessary shutdowns caused by Spectffcation

.4.0.3 when surveillance intervals are tnadverientl.Y exceeded. The solution ts to clar1fy the applieabtl'lty of the Actfon Requirements. to specify a spec1f1c ac:ceptable t 11111 1111f t for campl et1ng

lllf ssed surve1 11 ance 1n cert.tin cire*tances, artd to clarify when a missed surveillance constitutes a v1olat1on of the 0perab1lfty Requ1l"llllnts of 1n LCO.. It fs overly c

cons*rvatfve to ass-. th*t -t,YStems or c*ponents *re fnoperable when a survaf 11ance has not been performed becavse the vast majority of surveillances do in fact dtmonstrate that systems or components are operable. lifhen a surveillance is *issed, 1t 1s primarily a questfon of operability that has not been veri ff ed by the perfomnce **of a Survei 11 ance Requirement. Because the allowable outage time Hm.fts of some Ac.tfon Reqvirements do not provfde an appropriate t i

for performing a missed surveillance before Shutdown Requirements apply, the TS should include a tfme limit that allows a delay of required actions to permit the perfo,,..,nce of the rnfssed surveillance based on consideration of plant conditions, adequate planning, ava1labi11ty of personnel, the time required to perform the surveii lance. and, of course,. the safety sign1f1cance of tt.e 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 fs an acceptable tin limit for completinp a missed surveillance when th* allowable outage times of the Action Requirements are less than this, limit, or when time fs needed to obtain a temJ)Orary waiver of the Surveillance Requirement.

The third problem involves two possible confHets between Spec1fkatfons 4.0.3 and 4.. 0.. 4. The first confHet arises because Specification 4.0.4 prohibits entry f nto en operational mode or other specified condition when Survef11ance Requirements have not been performed within the specified survei11ance interval. A conflict with this requinH1Jent exists when a mode change is

~equired as a consequenee of Action Reguirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. S~ification 4.0.4 should not be used to prevent passage through or to operational modes as recJuired to comply with ~.ct1on Requirements because to do so: (a} would increase the potential for a plant

TSTF-529, Rev. 3

... 3 ..

,9 upset; and (b) would challenge safety systallS. Also, certain sunef11ance(

should be allowed to be performed during a shutdown to COll'lp1¥ With Action R9e1u1rements. Along wfth the 11Ddtf1catfon of Spee1f1cat1on 4.D.3 to 111r11ft a df1<<.r of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months fn the 1pplfcabfHty of Action Requf .--nts.

Specf ftcatton 4.0.4 hes been clarified to *llow passage through or to

operatfonal modes as required to camply with Actfon Re(fufNMnts.

A second conflict could *rise lttcause, when SUrYefllance Require1111nts ctn only be Cfll'IPlttad after entry f nto a mode or specfffed condition for which the Survenlanc:e Requ1 ....nu apply, an exception to the requf,..nts of Specff1catfon 4.0.4 ts a11Md. However, upon entry into this mode or condftfon, the requfN111nts.of Specfflcatfon 4.. 0.. 3 1111 not be aet because the Suf"Ye111ance RequfT'llllftts N.Y not have been perfonned within the allowed survafllance interval. Therefore, to avoid any conflict between Spec1ffcat1ons 4.0.3 and 4.0.4, the staff wants to make clear: (a) that ft ts not the intent of Spec1ff cat1on 4.0.3 that the Action Requirements preelude the performance of surve111a1'1Ct5 allowed under any exception to Spec1ffcatfon 4.0.4; *ml (b) tnat the delay of up to 24 houn 1n Speciflcatfon 4.0.3 for- the applicab111ty of**

Action Requirements now provides an approprfate time Haft for tN' ca11pletion of those Su1"Ve11Tance Requi,...nts that becmte applicable as a consequence of allowance of any exception to Speefftcation 4.0.4.

If 1ou have any questions on this 111tter. please contact your project nna99r.

Sincerely, k ! ~/j._

Fran!< J~~;<<;As::f1te for Projects Dfl'OCter

'Office of Nuclear fteactor Regulation

Enclosures:

As stated

TSTF-529, Rev. 3 Enclosure 1 to Benerfc'Letter 87-09 ALTERMTIV!S TO THE m REQU?AEM!m TO RESOLVE THREE SPECIFIC PR09LEMS WITH UMIT!NQ CONDITIOIS FOR OPERATJON AND SURYE'ILL~E REOUIREMEm rmooucrrOH Generic letter 87-09 discusses three problems regard1ng the general requ1r...-rts of Sections 3.0 and 4.0 of the*STS on the app1feab111ty of L1*1t1ng tondftfans for Operation (LCO) and SurYeflltnce Requ1re111ents. The guidance pravtded fn I

I this enclosure addresses alternathes to the Standard Teelmica.1 Specff1cat1ons (STS) to resolve these problas...

ProbllfJI #1 .... UNNECESSARY RESTRtCTtONS ON MODE CHANGES ($pecff1cat1on 4.0.3)

" BACKGROUND The definition of an LCO is given 1n 10 CFR 50.36 as the lowest functional ca,,Uflfty or performnce level of. eQU1J'llf8R't req11fred for safe operatfon of the facflityl' Further. 1t fs stated that when an I.CO of a nuclear reactor 1s not met. tlte lfcettsee shall shut down the reactor or follow 1n,y .--4111 action permitted by the TS until the condition can be 11et

Consistent with lfRC's Ngulator,y requ1MJ11ents for an LCO. the TS include i.o basic types of Action Requinments that are applicable when the LCO is not met. The first spee1f1es*the remedial actions that pennft contin.-d operation

of the facf11ty not restricted by the tfme l111fts of Action RequfP'll!!llllnts. la this case, conformance to the Action Requirements "]Jrovfdes an acceptable level of safety for continued operation of the facility. and operation may pl"OcH<f indefinitely as long a* the remedial Action Requirements are met. The second type of Action Requf l"ellltnt specifies 1 time Hanft in which the LCO *st be met. This ttme limit 1s the time allowed to l"Htore an inoperable sys* or component to operable status or to restore parlllllten wfthtn spectffed 1fllits ..

If these ac:tfons are not completed Within the allowable outage time l111tts.

action must be taken to shut down the facility by placing 1t fn a mode or condftfon of operation fn wtrlclt the 1.CO does not apply.

Speciftcatfon 3.0.4 of the STS states that entry into an oper<<tfonal llOde1 or other specified condit1on shall nt be made unless the LCO is met without reliance on the provisfon$ of the Actton Requirements. Its fntent is to ensuf'8 that a higher lllOde of operation fs not entered when equi.-ent ts inoperable or when parameters exceed their soec1f1ed Hmits. This precludes a plant start.up *

when actions are being taken to satisfy an Leo. tirhich -- ff not completed within the tfme limfts of the Action Requirements -- would result 1n a plant shutdown to comply with the ~ction Requirements.

. 1The BWR STS use the term "operatfonal condition" instead of tht! term

,,operaticnal mode" that is used 1n PWR STS. As used here, *operational mde 11 means "operational condition" for BWRs.

TSTF-529, Rev. 3 Specification 3.0.4 also precludes entering a l8C>cle or specified condition if an lCO ft not *t. even ff the Action Requirements would p11rmit continued operation of the faciHt.v for an unlimited period of time. Generally. the fndfY1dua1 speciffcatfons that have Action Retp,111 ements which all* contfnued operation note that Spectfteation 3.0.4 does not.appl1. However, exceptions to Specification 3.0.4 have not been eonsf.stently applied and their bases "' not welt docUJDented. For exlllf)le, approximately two-thfrds of the actions which permft contintad oper1tf on f n the Westfngbouse STS are exempt fl'Olft Spt'Cfficatf cm 3.0.4. Although ttttt staff encourages the 11a1ntenance of all plant systems and c:G11pOnents fn an operable condition as a good practice. the TS generally have not precluded entering a mode with inoperable equipment when the Action Requirements include ranecHal measures that provide an acceptable level of safety for continued operation.

STATalENT OF THE PROBlEM .

Jnconsf stent application of exceptions to Specification 3.0.4 impacts the operatton f.if the facilfty tn two lfl.YS. Ffrst. 1t delays startup under condf t1ons f n which conformance to the Action Rec;ufl"'ellents establishes an acceptable level of safety for unHmited continulHf operttfon o'f the '*cfT1ty.

Second, ft delays a return to power operation when the facility ts required to he in a lower llDde of o1)eratfon as t consequence of other Action Requirements.

In this case. the LCO must be at without reliance on the Action Requfrements before returning the facility ta that operatfonal mode ot other tpec1f1ed condition for which unlimited continued operation was previously pennftted fn accordance wtth the Action Requfrttllents.

0 STAFF POSITION ,,.

Specification 3.0.4 unduly restricts facility operation when conformance to the Action Reo.uirements provides an acceptable level of safety for continued operation. For lf'I LCO that his Action Pequirements penntttfng continued operatfon for an unlimited periOd of time. entry into an operational tnOde or other specified condition of operation should be permitted fn accordance wfth those Action Requirements. This is consfstent wfth NRC's regulatory requfrements for an lCO. The t-estrfct1on on a change in operational modes or other specified conditfons sf?ould apply only where the Action Requirements establish a specified time intel"Yal f n which the LCO must be met or a shutdown of the facility would be required. However. nothing in this staff Position should be interpreted as entfarsfng or encouraging a plant startup with inoperable equipment., The staff believes that pd practice should dfctate that the plant startup shoUld normally be initiated .only when all required equipment 1s operable and that startup with irioperabl* equipment must be the exception rather than the rule.

CHANGE TO SPECIFICATION 3.0.4 The practical solution to this problem is not the modification of TS to note that Specffica.tion 3.. 0.4 does not *PP1Y, but rather a change to Specification 3.0.4 to define the conditions under which 1ts requil"'eltents do apply.

Therafore. Specif'fcat1o" 3.0.4 w1l1 be revised to state:

TSTF-529, Rev. 3

Entry into an OPERATIONAL MODE or other SfM!Ciffed condition shall not be made when the conditfons for the l fm1tfng Conditions for Operation are n.ot met and the assocfated ACTION requf res 1 shutdown if tftey are not met wfthin a specffted ttme 1nterva1. Entry into an OPERATIONAL MODE or specfffed condf tfon may be made f.n accordance wfth ACTION requirements when eonfonnance to them permits continued operation of the facility for an unlfmfted period of time.u CHAHGES TO INDIVIDUAL SPECIFICATlONS EXEMPT FROM SPEClF?CATION 3.0.4 As a consequence of the modification described above to Specification 3.0.4, fndfvfdual specffieatfons wfth Action Requirements pe""ittfng continued operation no 1onger need to fndfcate that Speciffcatfon 3.0.4 does not apply. They should be revised to delete the noted exception to avoid eortfusf on about the appHcab11fty of Spedf1catfon 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 Specfficatfon 3.0.4 as revised. For exa,.le, some specifications would not satisfy the provfsions under which mode changes are pennitted by the revision to Specification 3.0.4 and, therefore. the exception to Specif1cat1on 3.0.4 need not be deleted. It fs not the staff's intent that the revision of Specification 3.0.4 should result 1n 1rt0te restrictive requirements for individual specifications.

Problem #2 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSING Qf sQP.vt1lfJR!:! t!f5!fflL$ {!pec!!foaUon ~.Q.!1

- BACkGROUND Surveillance Requirements are defined in IO CFR 50.36 as those rf!'qu1rements relating to test. calibration, or inspection to ensure that the necessary quality of systems and components 1s maintained, that the facility wi11 be within the safety limits, and that the LCO will be met ..

Consistent with the NRC*s regulatory framework for Surveillance Requfrements, Specification 4.0.3 states that the fa'f1ure to perform a surveillance ""ithin the specified t1me inter'\lal shall constitute a failure to meet the LCO's Operability R<<1uirements. 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 LCO'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 outa9e tiN Hmft) that permits corrective action to be taken to satisfy the LCO. When such a specified time interval 1s included in the Action Requirements, the completion of 1 misHd survei11ance within this tfme interval satisfies Specification 4.0.3.

STATEMENT OF PROBLEM Some Action Requirements have ailowable outage time limits rif only one or two hours and do not establish a practical time lfmft for the completio" of a missed Surveillance Requirell'lent. If surveillances cannot be completed witMn these

TSTF-529, Rev. 3 time limits, 1 plant shutdown would usually be required. Even if the Act1on Requirements include remedial measures that would penn'ft continued operation.

they may be stated 1n such *way that they could prevent the performance of the required surveillance. A plant shutdown* would also be required if the missed surveillance applies to more than the minilJIB number of systens or components reau1red to be operable for operation under the allowable outage time Hmfts of the Action Requirements. In this case, the individual specification or Specification 3.0.3 would require 1 shutdcnm.

If a plant shutdown is required before* a missed survefllance 1s canpleted, it is likely that it would be conducted When.the plant is being shut down because completion of a missed surveillance would terminate the shutdown requirement.

This ts 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 ch~nging plant conditions that offer the potential for an upset that could lead to a demand for the system or emponent being tested. This would occur when the system or component 1s. either out of strrice to allow f)e'rformance of the surveillance test or there fs a lower level of confidence in its operability because the nonral surveillance interval was exceeded. If the surveillance did demonstrate that the systet11 or cQl'.ftPonent was inoperable, 1t usually would be preferable to restore 1t to operable status before making a maJor change in

plant operatinf conditions. Second, a sbutdmm would incnase the pressure on the plant staf~ to exp8ditious11 complete the required sut"vef llance so that the plant could be. returned to power operatfon... This would further incT"ease the potential for a plant upset when both the shutdown and survetllance act1v1tfes place a .._nd on the plant operators.

0 STAFF POStTrOft ,,..

It 1s ove~ly conservative to assume that systems or components are inoperable c

when ,a survef llance requfretnent hat not been perforwd. The opposite ts 1n fact the case; the vast majority of surveillances demonstrate that ~ystems or components in fact are operable. When 1 surveillance fs mfssed, it is primarily a questfon of operabtlfty that has not been* verified by the performance of the required suryeil11nce. Because the allowable outage time limits of some Action Requirements do not provide an appropriate tflle 11m1t for perfonning a missed surveillance before shutdown requ1.rements may apply, the TS should include a time limit that would a.now a delay of the required actions to permit the performance of the mfssed surveillance.

This time limit should be based ott consicfel"'atfons of plant conditions. adequate pl1nntny, avaf1ab11fty of personnel, the time required to perform the survefl ance, as well as the safety significance of the delay in completion of the survecnlanc:e. After reviewing pouihlft 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 1 missed surveillance when the allowable outage times of the Action Requirements are less than this tiM limit or when shutdown .lctfon Requirements apply. The 24-hour time limit would balance the rfsks associated with an allowance for cmip1etinv the surveillance within this period against the risks associated with the potef't1a1 for a plant upset aftd challenge to safety systems when the alternative is a shutdown to comply with Actforr Requirements I before the surveillance can be completed. ...........

.. 4 -

TSTF-529, Rev. 3

<'~,

r.*\*1*:**t*

J.

A.lthoulh a missed. suPYef111nc1 would generally be cmpleted in less time than this 24-hour 1t111t allows, spec111 circumstances 1r111 requfre 1dd1tfon1l ttme to ensure that the 1urv1i l11nct can bl conducted ht a sift .,,,....

The ti*

11mts of Actfon Requireents for suPYefllanc.s should start llfhen ft fs fdentiffed that survatllance Requirements have not been performed, except when the Zit.hour delay ts allowed fn the fmpT..,.t1tfon of' the Action Requ1rements.

Where the 24-hour tfme lfmft it allowed, the time lfmfts of the Action

Requirements are 1pp11cab1e either et the end of th~ 24-hour lfmft ff the

survt111ance h.as not beet1 canpleted or at the time the Sllt'Yef11ance fs perfo,..d ff the systa or ttlllPOftl"t f s found to be inoperable. :

Several issues need to be clarf fiecf regarding the 1dd1t1on1T 24-hour tfme 1fmft. Ffrst, thfs limit does not waive c~11ance With Specfff cation 4.0.3.

Under Speciffcatfcn 4.0.3, the faflure to perfonn 1 surveillance Requirement Will continue to cottstitute nonc0111P111nce wtth the OperahfHty Requirements of an LCO and to bring into play tit* apptfcab1e Action Requirements,.

second, Specffic1tions 3.0.2 and 4.0.3 should net be mfsirtterpreted.

Specification 3.0.2 notes that a TS fs befng complied w1th wtten the Action Requfrenmts are met within the s 1f1ed time fntervals. Although Spec1ffcat1on 4.0.2 provides an a lowance for extending the survefllance interval and a11ows for the c*p1etion of the surveillance within this tfme interval without vfolatfon of thfs Speciffcatton, under Spectffcatfon 4.0.3 nonperfot'ltlnce of a Surveillance Requirement, w1th1n th' allowed surveillance interval deftned by Spteff1cat1on 4.0.Z, constitutes a violation of the

.Operabf lity Requirements of an LCO. H defined by Specfff eation 4.0.3. ahd is subject to enforcement actfon

To avofd any conflict 11110nt or m1sreacHn9 of' Specilfications 3.0.2, 4.0.3, ahd 4.0.2, the staff wishes to mete clear (1) that Specffication 3.0.2 shall not.be constl"Ued to imply that the completton of a missed surveillance w1thf n the allowable outage time Hmits of the Action Requirements -- whether or not the addftfonal 2.4-hour time Hmtt is included -- negates the ~iolat'fon of Specificat1on 4.0.3. and (2) that the failure to perform a surYef11ance within the allowable surveillance tnterval defined by Spectf1eat1on 4.0.2 constitutes a reportable event under 10 CFR 50.73(a){2)(i}(B} beeaute it is a condition proh1b1ted by tha plant's TS.

Third, even though an additional 24-hour time limit may apply for missed survef11ances, another consideratfcn is the possfbflity that plant conditions may preclude the performance of the spec1ffed requirements~ The prevision of a 24..hour delay 1n the application of the Action Requirements far the completion of a missed surveillance would provide time to obtain a temporary wa1ver of a Surveillance Requirement that could not otherwise be completed because of current plant conditions. If 1 surveillance can be performed only when the plant is shut d°"11, there are only two options available to licensees when a missed surveillance fs discovered during power operation and continued operation is not allowed r.rnder the Action Reoutrements. The first f s 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 TS amendment. As a matter of exfstfng policy,. a temporary wafver of compliance with 1 TS that would unnecessarily require a shutdown or

.. 5 -

TSTF-529, Rev. 3 delay startup absence of s - relief may be granted by HRC. A te.itporary waiver- of ccmpliance may be granted ff the lfeensee has dlmonstl"ated in a written submfttal. provfded before the TS LCO expired, that the facility can safely conti* to operate w<thout compliance wftJt the TS during the ttme ft e "

will take to process the TS aandment. request.

CJWIGE TO SPECIFJCATIOH 4.0.3 Spec1ffcatfon 4.0.3 Will be revised IS follows to clarify when a missed surveillance constitutes a violation of the Operabflft.Y RequfJ"81!flents af an LCQ

ltd to clarity the app11cabf11ty of the Action Requirements and the time during which tt.e* Hwtts apply: .

"Fanure to perform a Surveillance RequiNtnent within the allowed surve111tnce interval, deffned by Speciffcation 4.0.2, shall constitute noncompliance, wfth the OPERABILITY requirements for a Limiting Condition for Operation... The time limits of the ACTJOH requirements are applicable at the tinre ft 1s identified that 1 Surveillance Requirement has not been performed. The ACTION requf rements 11111 be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to pennt.t the campletion of the surveillance when the allowable outage time lfnnts of the ActION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

Specff1cat1on 4.0.3 previously included the statanent that exceptions to it are stated in 1nd1*1dua1 specifications. This statement is deleted because Specification 4.0.3 is always applicable. 1.e** the fmpHed exceptions for

'fnd1V1cful spec1f1c.atfons do not exfst.

Problem 13 ..... CONFLICTS BETWE!tf SPECIFlCATfONS 4.0.3 AffD 4.0.4 I'-*

RfLAfiD TD Jll!Pg eRAJ&tl csijF1f1cat1on !.o.!J Tttere.1re two parts of the geftfral*problem of conflicts between Spec1f1cat1ons 4.0 *.3 ind 4.0.4 related to tnOCte changes. Eich of these parts h dhcussed separately below.

Part 1 -- SURYEI~ REIREMENTS THAT BEmtE APPLICABLE QUE TO ACT!ON

R!DQ!B~~ ~ .

STATEMENT OF THE PROBLEM Specificatton 4.0.4 prohibits entry into an operat1ona1 mode or other specified condition when Surve1l1ance Requirements have not been perfor.d wftb1n 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 wt.en the Surveillance Requirements that become applicable ha¥e not been perf'onlled withfn the specified surven 1anee interval. For instance, the plant could pre:v1ous1y have been in a 110de for which the Survetl11nce Requirements were not applicable and, therefore. the surveillanc* may not have been perl'ormed within the specified t1are interval. Consequently, the Action Requirements of the LCO associated with these Surveillance P.equirements apply and the unit may have to be placed in 1 lower mode of openst1on than that requ1red by the *

, original $hUtdown Action Requirements, or other remedial actions may have to be \...

... 6 -

TSTF-529, Rev. 3 t' "

taken. ff the surve11lance cannot be COllPleted within the tfme limits for these actions. This is a second problem that may be encountered.

The first problem arises because conformance wfth Specfff cat1on 4.0.4 would requf re the perl'ormance of these. survei 11ances before entering a mode for whfch they apply. Source and intermediate range nuclear instMMntatfon and cold ov1J'P1"9ssure protection systems 1n Ms are exUIJ)les of systems for which Surveillance Requirements may become applicable as a consequence of mode

changes to comply with shutdown Action P.equ1remenu. The second problem has been mitigated by the change in Speciff cation 4.. D.3 to pennit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1n the appHcabflfty of the Action Requframen-u, thereby placing an appropriate time limit on the completion of Surveillance Requirements that .

become applicable as a consequence of mocJe changes to camply w1th Action

Requfrecaents.. However, the first problem can be further resolved by a chenge to Specffication 4.0.4.

0 STAFF l'OSITION The potential for a p1ant upset and challenge to safety systems fs heightened ff surveillances are perforNd during a shutdown to comply wtth Action Requ1Nnents.

tt is not the intent of Specif1cat1on 4.. 0.. 4 to prevent passage thrOUfh or to operational modes to emply -1th Action Requfranents and ft should not apply*

when mode changes are imposed by Actfon Requirements. Accordfngly, Speciffeatfon, 4.0.4 should be modified to note that its_ proYfs1ons shall not prevent passage through or to operational lllOdes as required to comply with

Action Requtrements. A s1_1n11ar p.-ov1sfon is included in Specification 3.0.4 *

CHANGE TO SPECIFICATION 4.0.4 The followtng will clarify Specif1ca,tfon 4.0 .. 4 for mode changes as a consequence of Aetton Requirements:

ltfhfs provfs1on shall not prevent passage through or to OPERATIONAL IWODES IS requfred to comply with ACTION RequfNlllents.

Part 2 *- SURVE'ILLAMCE RE~J!fEMENTS FOR EXCEPTIONS TO SPECIFICATION 4.0.4 0 STATEMENT OF THE PROBLEM An eicept1on to Specificatfon 4.. 0.4 1s allowed when Suf"Ye111ance Requirements can be completed only after entry into a mode or specified condition for which they apply. For example, the TS on power distribution limfts are generally exempt from Specification 4.0.4.. However. upon entry into the mode or specified to1'dftion, Spec1fkation 4.0.3 may not he 11et because the Surveillance Requirements may not have been performed within the allowed surveillance interval.. Generally. these Surve111ance 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 Spec;:1ficat1on 4.0.4 can create a conflict with Specification 4.0.3.

TSTF-529, Rev. 3 STAFF POSITION It is not the intent of Sfl4'cfffcation 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 peM!lit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the app1fcabi11ty of the Action Requirements. an appropriate time lfmit now exists for the completion of those Surveillance Requirements that become applicable when an exception to Specification 4.0.4 is allowed.

c TSTF-529, Rev. 3 Enclosure 2 to Generic Letter 87-09 3/4 LIM!TUfG CONDITIONS FOR OPERATIC~ AND SURVElLLAllC! !fOUJREMEJfTS 3/4.. 0 .APPpCABILlTY

[NOTE: Only Specf ficat1ans 3.0.4, 4.0.3, and 4.0.4 are bef ng llOd1f1ed, as shown in the uncr.rHned prov1s1ons. The other spec1ficatfons are shown for informatfoft only.]

LIMITING eof4DITIOJIS FOR OPERATION 3.0.1 Colwpliance W1th the Limiting Conditions for Operation contained fn the succeeding specff1catfons 1s required.during the OPtRATIONAL MODES or other conditions specified therein; except that upon failure to 11eet the Limiting Conditions for Operation. the associated ACTtOH requirements shall be met.

3.0.2 WOncompl1ance wfth 1 specffication shall exist when the requirements of the limiting Condition for Oper1t1on and 1ssocfated ACTION requirements are not met within the specified Ume intervals. If the Lf111itfng Condition for Operation 1s restored prior to expiration of the specified t1me tntervals, COlftPletion of tht ACTION requit"elllents 1s not required.

3.. 0.. 3 When a Limiting Condition for Operation is not Jllet, except as provided 1n the associated ACTtON requfn1*tr1ts. wfthin l hour action shall be 1nftfated to place it, as applicable, in:

a.

At least HOT STANDSY 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 COLO SHUTDOWft within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where cof"l"'ectfve measures are c(lllpleted that pennit operation under thi! ACTION requfrementst thi! action IRIY be taken in accordance wfth the specified time 11m1ts as 111easured fl"'Ol'R the time of faf1ure to meet the Limiting Cor.dftion for Operation. Exceptions to these requirements are stated in the 1nd1v1dua1 speciffcat1ons.

This specification is not app11cab1e in MODES 5 or 6.

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made when the condttfons for the Limiting Condftfons for Operatfon are not met and the a!sociated ACTION f"eOUires a shutdown if the1 are not met with1n1 sQ!cHiea time fnterval. rntB into an oP!RA110RAL MODE or ssci1iii.i '.

cOi'idhion ma.y be maCle ln acco ance with lfTIDR ~frements e-n conformance to tfiem rnnts continued o ratlon of Bi fadl for an un1 tmnea erfod o s prov s on s a no preven passage roug or o as reQu1red to comply with ACTION requirements. Exceptions to these

requirements are stated 1n the individual spec1f1cat1ons.

PWR STS 3/4.0-l

TSTF-529, Rev. 3 APPLfCABILITY SURVEILLANCE REQUIREMENTS 4.0.l Surveillance Requirements sh~11 be met during the OPERATIONAL MODES or othe.r conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an ind1v1dua1 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 2S% of the surveillance interval, but

b. The combined time interval for any three consecutive survei1lance intervals shal1 not exceed 3.25 times the specified surveillance interval ..

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined b' Specification 4.0.2, shall eonsHfote noncomp1tance with the 0PERA81t1 Y requlrements ,or a Lfntitfng Condition for Operation. The t1me limits cf the ACTION l'"!!qUfrements are applicable at the time it is 1denHfhkl that a Survef11anee Re~Jrement fias not 6een eeH'ormea. Tfie ACi?DN refuiremenfs 1n4y fie de1ateN regu rements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1. z. and 3 contponents shall be app11cab1e as follows:

a. Inservice inspection of ASME Code 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 wfth Section XI of the AS~f Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR so. Section 50.55a{9), except where specific written relief has been granted by the C011J11ission pursuant to 10 CFR so. Section 50.55a( g) (6)( 1).
b. Surveillance intervals specified in Section XI of the ASHE 8of1er and Pressure Vesse1 Code and applicable Addertda for the inservice inspection and testinp activities requi~d by the ASME Boiler and PWR STS l/4.0-2
TSTF-529, Rev. 3 APP,UCAl!LIJ'Y sumnLMCE REQVI!lm!TS Pressure Vesle1 Code arid applfcabl* Addenda shill be 1ppl tc:able as follows fn thtl* Ttehn1c&1 Spec1ffcat1ons:
ASME Boiler and Pressure Vessel Rlqufrect frequencfes Cod* and appHC.bl* Addtndl for perl'ormfng f nservf ce tenn1no1ogy for 1nservice 1nspect1on and testf ng 1nseect1on and bJtfnt IE!fYftfes f'~s1.,.v~1t.1es~
R e e k t y t 1 e a s t once pel" 1 3ays Monthly At least ottCe per 31 days Quartef'"1,y or eYef'.Y 3 *nths At least once per 92 days S.fannua11y or em-; I 110rttfts At least once per 184 days Every 9 months At least once per 27fi days Yearly or anttually At least once per 366 days
c. The provisfons of Specfffcatfon 4.0.! are applfcable to tfle above required frequencies for performfng fnservfce inspection and testing actf vf ties.
d. Performance of the above f nservf ce inspection and tasttnt activities shall be fn acklitfort to other specfffed Surveillance Requfl"lllltnts.
Nothing ff! tn ASHE loner and Pressure Vessel Co* shall be c01tst111td to supenede the requf Nllf!flts of an.r Teclmf cal Spectficatfon. "'
PWR STS 3/4.0-3
TSTF-529, Rev. 3 Enclosure 3 to Senerf c Letter 87-09
~1f1cation 3.0.1 through 3.0.4 establish the genel"ll requirements 1pp11c&ble Clii1Un1 coriiHt1ons for llperaiton. These requirements .,.. based on the require111nts for L11111t1ft9 ComHttons for Operation stated fn the Code of Federal Regulations, 10 CFR S0.3'{c)(2):
"L1lt'lt1ng conditions for operatfon are the lowest functional capability or performance levels of equfJlftlnt NQuired for safe operation of the fac111ty.. When a 11mft1ng conditiOft for operation of a nuclear reactor is not met,. the licensee shall shut down the reactor or follow 1111 retned1al action penritted by the technfcal specif1cat1on untn the condition can be at.*
S~ificatign 3.0.l establfshes the Appl1cabi11ty statllnent within each 1n vfaiii1 spec1ffcatfon as the reqvirwnt for When (1.e., 1n which OPERATIONAL MODES or other specified conditions) conformnce to the l1*iting Conditions for Opention 1$ requfNCI for stfe operation of the faetlfty. The ACTION requ1retnents establish those remedial 11easures that 111st be taken wftnin speeff1ed tiine lfmfts wtH!n the refJUf1"'8111nts of a Lfmftfng Condftfon for Operation are not met..
Then! an two basic types of ACTIOM requ1t'f!lllftts. "ftte first spec1f1es the remedial measures that pena1t continued operation of the facilfty whfc:h is not further restricted by the t111e 11mfts of the ACTlOft requirements. In this case, cont'o.,.nce to the ACTlON requf'rements J>roY1des an acceptable leve1 of safety for unlimited continued operat1o~ as long as the ACTION reo.uit"ellents continue to be met. The second type of ACTIOtt requirement specifies a time 11m1t in which confonnance to the eond1t1ons of the Limiting Condition for Operation 111Ust be met. This tfm limit is the allowable outage t1me to restore '" fnoperable system or crnponent to OPERABLE status or for restoring parameters within specified 11m1ts.. If these actions are not completed Within the allowable outage time limits. a shutdown ts requfred to place the facflfty in a MOD£ or conditiOl\ in which the.spec1f1cation no longer applies .. It is not intended that the sbcltdoWn ACTION requirements be used as an o"rational convenience which pemits (routine) voluntary removal of a system(s) or camponertt(s) from service 1n lfeu of other a1ternatives that would not result in redundant systems or toraponents befng inoperable.
The specified tfme 11m1ts of the ACTION requirements are applicable from the pofnt fn tfme it is identified that a Limiting Condition for Operation h not met.. The time limits of the ACTION requirements are also app1 icable when a system or 'component is removed from service fer sul"Veillance testing or 1Jr1estigation of operational problems. Individual specifications 1ray 1nc1ude a specified tiJDe limit for the completion of 1 Surveillance Requiranent lift'len
, equipment is removed 'from service.. In this case, the allowable outage time PWR STS s 3/4.0-l
TSTF-529, Rev. 3 3/4.0 APPLICABILIT~
BASES (Con't) limits of the ACTION requirements are.applicable when this 11m1t 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 Wft1ch a new specification becomes app1icab1e.. In this case, the time limits of the ACTION requirements ~ld apply from the point in time that the new specificatfon becomes applicable if the requirements of the Lfmiting Condition for Operation are not met.
!Jiec1fication 3.0.2 estab1i~hes that noncompliance with a specification exists en the reoufrements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that
{l) implementation of the ACTtOff requirements within the speciffed time interval constitutes compliance wtth 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.
S~cif1cation 3.0.3 establishes the shutdown ACTION requirements that must be imp1etnenfea When a limiting Condition for Operation 1s not met and the condition is not spee1ffeal1y addressed by the associated ACTION requiraenu ..
The purpose of this specification 1s to delineate the time limits for plaefng the unit in a safe shutdown MOOE when plant operation cannot be maintained within the limits for safe operation defined by the U1t1tfng Conditions for Operation and its ACTION requirements. !t 1s not ~ntended to be used as an operational convenience Wh1ch permits (rot1t1ne) voluntary removal *of redundant systems or components f1"01ft service in lieu of other alternatives that would not result 1n redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This t1me permits the operator to coordinate the reduction in electrical generation with the load dispatchl!r to ensure the stability and avai1ab11ity of the electrical grid. The time limits specified to reach lower MODES of ~peration permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the coo1d0tim capabilities of the faci1ity assuming only the minimt.rm ret:1uired equipment is 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 whfeh thfs spec:ifftation applies.
If remedial measures pel"l'l'Jitting li~fted continued operatfon of the facility under the provf sions 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. 3 3/4.0 APPLICABILITY PMES (Con't)
The t'fme Hmfts of Specfffcaticm 3.. 0.3 allow 37 hoars for the plant to be fn the COLD SHUTDOWN l<<JDE when e shutdown is requ1!'ed dUl*1ng the POWER MODE of operation. If the plant 1s fn a lower MODE of op&Ntf on when
shutdown is required. the t1111e lf11it for reaching the next lower~ of operation ap-plies. However, ff a lower MODE of operation is nached in less time than allowed, the total allowable tilll to reach COLD SHUTDOlill, or other applicable MODE, is not reduced. For example., 1f HOT STANDBY fs reached f n 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach HOT SHUTDOWN 1s the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months because the total ti*
to reach HOT SHUTIJOWtt is not reduced ff'Oll the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ..
Therefore, 1f remedial measures are completed that would permit a return to POWER operation. a penalty fs not incurred by having to reach a lower 1110£ of operation in less than the total tiflle allowed.
The Saine principle applfes with regard to the allowable outage t1me 1111ffts of the ACTIOIC requirements, 1f canpliance with the ACTIOH requ1nnents for one specfffcation results fn entry fnto 1 MOD£ or cortditfon of' operation for 1nother spac1ficat1on fn which the requirements of ~ Lt*1tfng Condition for Operation are not met. If the new specification beCOllleS applicable 1n less t1me than specffied, the difference uy be added to the 1llow.b1e outage tfme limits of the second specff1cation. However, the allowable outage time limfts of ACTION requirements for a higher MODE of oper1tfon"11111 not be used to extend the all*ble outage tfM that 1s appl 1cab1e when a L11111t1ng Condition for Operation 1s not met in a 1ower MlOE of operation.
The shutdown requirements of Specfffcetion 3.0.3 d& not apply in MODES 5.and 6, because the ACTION requira11ents of f ndf v1cfual speciffcations define the remedfal 11easures to be taken.
S~if'fcation 3.0.4 establishes Hm1'tatfons on MODE changes when a Limiting Wn1tfon 'for Operation is not met. It precludes placing the facility 1n a hfgher tl>DE of operation when the requirements for a lftrftfng Condftion for Operation are not met and continued noncompliance to these conditions would result in a shutdown to tCllQ>lY with the ACTION requ1re1tents ff a change in MODES were penn'ftted. The purpose of this spec111cat1on fs to ensure thet facflity operation is not fnftiated or that higher MODES of operation are not entered when correetfve action fs being taken to obtain compliance with a spec1f'icatf on by restoring equipcnent to OPERABLE status or parameters to spec:fffed limits. Compliance with ACTION requirements that penntt continued operatfon of the facility for an unlfmited period of ti* provf des an accept-I able 1eve1 of safety for continued operation without regard to the status of I the plattt before or after a MODE change. Therefore. in this case, entry into an OPERATIONAL MODE or other specffied condition may be made fri accordance with the prov1s1ons of the ACTION requirements. The provisions of thi$
specifiertion should not. however, be interpreted as endorsing the.faflu" to
.exercise good practice 1n retor1ng systems or components to OPERABLE status before plant startup.
PWP. STS 8 3/4.0-3
TSTF-529, Rev. 3 3/4.0 APPLICABILI.Jl BASES (Can't)
When a shutdown fs required to emply with ACTION requirements, the provisions
(
of SPtcfficatfon 3.0.4 do not apply ~cause they would delay placing the fac111ty in a lower MODE of operation.
Seffficatfons 4.. 0.l through 4.. 0.5 establish the general requirements lpp1cab1e to Surve~11ance Ri(fuirements. These requirements are based on the Surveillance R~uf,...nts stated 1n the Code of Federal Re{ffllations, .
10 CFR 50.36(c){3):
"Suneflla.nce requirements are requfrements relating to test, calibra-tion. or f"spection to ensuf"e that the necessary quality of systems and components 1s mafntained, that facility operation wf11 be within safety limits, and that the 1im1t1ng conditions of operation will be met."
~if'icatfon 4 .. 0.1 establishes the requirement that surveillances must be onned durfng tfie OPERATIONAL MODES or other condft1ons for which the requirements of tbf Limiting Conditions for Operation apply unless otherwiH stated fn an tndfvfdual Survefllance Requfranent. The purpose of this specf-f1eat1on is to ensure that surve11lancet are performed to verify the opera-tional status of systems and components and that parameters are w1thfn specf*
f'fed limits to ensure safe operation of the facility when the plant is in a MOD£ or ottter specified condition ..Yorwhfch the associated Limiting Conditions for Operati<>n are applicatila. Sutvefllance Requfr111ents do not have to be perfOf'lled when the facility is fn an OPERATIONAL MOOE fOf' which the requirements (
of the 1ssociated Umftfng Cond1tfon for Operatiorf'do not apply unless otlterwise .
specified.. The Surve111aftee Requirements associated with a Special Test -
Exception are only applicable when the Special Test Exception f s used as an allowable exceptfon to the requtrcents of a speefffcation.
SJl!Sification 4.0.t establishes the eof\dftfons under which the specified time lnterva1 for Surveillance Requirements may be extended. rtem a. pemits an allawtble extension of the normal surveillance interval to facflftate surveillance schedtllfng and cons~derat1on of plant aperat'fng conditions tnat may not ba suitable" for conducting the surve111ance; e.g., transient conditions or other ongoing s.urvef1tance or meintenance activities. item b. limits the use of the pro*lfsfons of item a. to ensure that ft is not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are based on engf neerfng judgment and the recognf t1on that the mcst probable nsult of any particular surveillance being performed f s the verification of conformance w1th the Surveillance Requfl"efllents. These provisions are sufficient to ensure that the reliability ensured through surveillance activft.fes is not signtfteantly degnded beycnd that obtained from the specified surveillance interval.
eeefficat1an 4.. 0.3 establishes the faflure to perfonn a Surveillance quirement i'Hfih1 the allowed surveillance interval, defined by the provisions of Speefffcat1on 4.0.2, u a condition that constitutes a failure to meet the
OPEMiHLITY requif'etnents for a limiting Condition for Operation. Under the PWR STS B 3/4.0*4
TSTF-529, Rev. 3 3/4.o APPl;ItABIL!TY
BASES (Ccm't) provfsions of I
tftfs specification, .s1stem altd ccnponents are issumd to be 08£RABLE when Surven lance Requirements h&~e been satisfactorily perfonned within the specified ti* interval. However, nothing 1n tflfs provfsion*1s to be construed as f11p1ying that systau or t0111pOnents are OPERABLE when they al"e f'ound or known to he 1nopeJ"tl>le although stt11 11eet1ng the Surv-e111ance Requirements. This spec1ficat1on *1so clarifies thet the ACTION requf1ements are applicable when SUneUlance Requiraents have not been c*leted within the allowed sune111ance interval and that the time limits of the ACTION requirt1J111ts apply from the paint 1n ti111e ft 1s identified that a surveillance has not been performed and not at the tf1111 that the allowed surveillance intef"Va1 *s exceeded. Collplet1on of the Surveillance* Requirement with1n the allowable outage t i
Hmits of the ACTION nqufrements restores eomplfance with the requ.1re111ents of Specfffcatfon 4.0.3. However, this does not negate the fact that the failure to have perfonned the surveillance wfthfn the allowed surveillance interval deffned by the provtstons of Specfffcatfon 4.0.2, was a violation of the OPERABILITY recf<<frtments of a Li11fttn9 Cortdftfon for Operation that* 1s subject to enforc-.nt action. Ftn"ther. tM failure to perfonn
surveillance wftf't1n the provisions of Specification 4.0.2 fs a vfolatton of a Technical Speefffcatfon nquirement and ft, tftttt*refore. a Nportable event under the requirell8nts of 10 CFR 50.73(aJ(2)(i)(BJ because 1t is 1 condition prohibtted by the plant.*s Technical Specfffcatfons *
I.f the allowable outage tiile ltll'lts of tM ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown ts required to CC9P1Y with ACTION requtremnts, e .. g.,
. Spec1f.1cation 3.. D.3, a 24-hour allowance is providtd to pennft a delay tn fmplement1ng the ACTlOI requirements. Tttis provides an adequate time Hmft to complete Surveillance Aequtrements that trave not been perlormd,. The purpose of th1.s allowance 1s to -perrift the carspletfon of a surveillance before a shutdown is requf red to comply with ACTION requirements or before other remedial measures would be requited that 1111.Y pNclucfe ca11plet1on of 1 turvefllance. The basis for thb allowance tncludes eonsfdera.t1on for plant conditions. adequate. planning., avaf1ab111ty of personnel. the time requ1r-td to perform the survefllance, and the safety significance of the delay 111 completing the requited sut"'Veilbnce ... This provision also ,n*ovtdes a time 1fmit for the complet~on of Surveillance Requf\"'elleftts that became applicable as a conseqbence of MODE Changes fllPOSed by ACTION requil"elltnts and for cmnpleting Surveillance Requtre11ents. 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 tfme Hllits of the ACTION requirements are applicable at that time.. When a survefllance is performed within the 24-hour allowance and the Surveillance Requirements are not met., the time lfmfts of the ACTION requirements are app11cable at the t1me that the surveillance fs terminated ..
Surveillance Requtrements do not have to be performed on inoperable equfpment because the ACTIOft requfrements define the remedial measures that apply.
However, the SurY&fllance Requ1rements have to be rr.t to demonstrate t~at
~, inoperable eqttf pment has been restored to OPERABLE status.
PWR STS 8 3/4.0-5
TSTF-529, Rev. 3 314.0 APPLICABlpTY BASES (Con't)
Specfffcation 4.0.4 estabHslta. the requirement that 1l1 applfcable survtf1lanc11 must 6i meE tiilore entry 1nto an OPERATIONAL MODE or other cond1tf on of operation specfffed in the App11cab111t,y statement. The purpose of thi $
spec1f1catf on 1s to tMtsure that s.vstent and COlfPOnent OPERABIL?TY requf 1"1Mtnts or parameter limits are mt before entry into a MOOE or condf t1on for which these systtms 1nd COiftPOrtertts ensure safe oper~t'fon of the facf11t,y. This provf sf on app*t ies to changes fn OPEMTIONAL fl!ODES or other spec1f1ed condf tfons associated with plant shutdown as well as startup.
Under the provfsions of thfs specffication, the applicable SUrvef11ance Requfre111ents must ~ performed wfthin the specfffed surve111ance fnterval to ensure that the Lfmftfng Condftfons for Operation are *t during 1n1t1a1 phnt startup or following a plant outage.
When a shutdown 1s r"ufred to eonply with ACTlON requ1l"elents, the pnvts1ons of Spec1f1cat1on 4.0.4 do not a,Ply because this wauld delay placing the facf Hty fn a lower MOOE of oper1tfon *
.H;ff1cat1on 4.0 ..,5 establishes the requfrwnt that insenice inspection of tOde ~1ass 1. 2, and 3 C011pcments and fr.service testing of ASME Code Class l. 2, and 3 puMps and valves shall be performed in accordance with a periodically. updated version of Section Xt of the ASME Bof1er and Pf*essure VeHel Code and Addenda as required by 10 Cf'R 50.SSa. These requfretnents AJ>PlY except when relief has been Pt'OVided in writing by...the CC9!1ssfot1.,
Thf s specit'1catfan includes a cltJ"fffcatfon of the frequencies for performing the 1nsen1ce inspection and test1ng act1v1t1es required by Section Xt of the ASME Boner and Pressure Vessel Code and app11cable Addenda. Thfs clarfffcation is provided to ensure consistency in survefl11nce intervals throughOllt the Technical Specf ff cations and ta 1"9IOVe any ad>.tguities relative to the frequencies far perlormfng the requfru 1nserviee inspection and testf ng activf t1es.
Under the terms of this specffieatfon, the more restr1ctfve requirements of the Tectm1ca1 Specifh:ations take precedence over the ASME ~oiler and Pressure Vessel Code and applicable Addenda. The requirements of Specff1catfot'l 4.0.4 to perform surveillance 1ct1v1t1es before entry into an OPERATIONAL MODE or other specified cond1t1on takes precedence over tne ASME Boiler and Pressure Vessel Code provision which 1Hows pumps and valves to be tested up to one week after return to normal operation. The Technical Specification definition of OPEAABlE doe$ not allow a gra.:e period before a component. that 1s not capable of performing its specified functfon. 1s declared inoperable a.nd takes precedence over the ASME BoHer and Pressure Vessel Code prov1sfon which allows a valve to be incapable of performfng fts specffied function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before be1ng declared inoperable.
PWR STS
TSTF-529, Rev. 3 Enclosure 4 to Generic letter 87-09 3/4 LIMITING CONDlTlONS FOR.OPERATION ANO SURVEILWCE REQUIREMENTS
~4.0 APPLICA8ILITY
[NOTE: Only Specfffcat1ans 3.0.4. 4.0.3, and 4.0.4 are being llOd1f1ed, as shown in the underlined provisions. The otfM!r specificatians are shown for f nfonnatf on only.]
. LIMIT!HQ CONDITIOlfS FOR OPERATION 3.. 0.l Compliance with the Lfmftfng Conditions fo1" Operation contained fn the succeeding Specifications is required during the OPERATIOIAL CONDITIONS or other condf tfons spec1ffed therein; except that upon failure to meet the Limiting Conditions for Operation. the associated ACTION requirements shall be met.
3 .. 0.2 loncomplfance wfth 1 Specfffcatfon $hall extst when the requirements of tire lflritfng Cond1tton fer Operation and associated ACTlONrequiremeJtts are not met withtn the specified tfme ihtervals *. If the Lf11fting Condition for
°"'ration fs restored prior to expiration of the specified ti* intervals, C:Ofllpletion of the ACTION requirements ts not requfred.
s. o.3 When a Lfmit1ng Candf tfon for Operation is not Met, except as provided fn the associated ACTION requfrements, ttfth1n one ltaur action shall be fnftiated to place the unit 1n an OP.ERATIOHAL CONDITION 1n which the Spec1ff cet1on does not apply by placing it. a applicable, 1n:
l ..
At least STARTUP wtthfn th* next 6 hol.ln.
2. At least HOT SHUTDOWH wftbin the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and
3. At least COLO SHUTOOWI within the subsequent 24 houl"S.
Where corrective measures are canpleted that permit operation under the ACTION requfrements, the actfon may be taten in accordance Wfth the specified time limits as measured fr'Oll the tfme of failure to meet the Lfmttfng Condition for Operatfort. Excttpttons to these requirements are stated in the individual Specff1cations.
This spee1f1cat1on is not appUeable in OPERATIOHAL CONDITION 4 or 5.
BWR STS 3/4.0-1
TSTF-529, Rev. 3 APPLICABILITY SURVEILLANCE REgD1REMEffTS 4.0. l Surveillance Reqvireients sha1.1 be *t during the OPERATIONAL CONDITIONS or other conditions specified for ind1v1dua1 Limiting Conditions for Operation unless otherwfse stated fn an individual SUrvefl lanc:e
Requirement ..
4.0.2 Each SUrvei111nce RequiN'llent shall be performed wtth1n the specified time intena1 with: * .
a. Amaximum allow1bJe extensfon not to exceed 251 of the survtfllance interval. but
b. The combined tfme interval fof" any 3 consecuttve surveillance fnterva1s shall not exceed 3,.25 ti*s the specfffed surveillance interval.
4.0.3 Faflure to perform a Surveillance Requirement *fthfn the all<Mffed surveillance fnterv11. defined b~ SR!$1fjcation 4.0.2. shall consi16ite noncompl,ance wfth the lJPfRXlttJ Yre<tulremenfs for a Limiting Condition for Operation. The tflbe lfmfts of the ACTION reguirements ere IJ!!Hcable at the time it is foenftffid tliat a !urvef11ance AeJufrement has not &!in r
2!r=foiiiid. Thi mtoR Nmremenb may J5i de1*f Ol" UP to H hours to
\!;nnft the c'111etion of surv*fl11nce When e a11oWi61e outaff time mHs o'I illitfibN regu rements are less than ~i'tliilrs. survef ance I lequfremen'ti do not 6ave to be performed on 1nope b1e equipment. ~,,_
4.0.4 Entry into an OPERATIONAL CONDITION 01" other specified applicable condition shall not be made un1es$ the Surveillance Requirement(s} associated with the L111tftfng Condition for Operation have been performed within the applicable surveflhnce interval or as otherwise specified. Tflfs provision shall not 1revent eassale through or to OPEP.ATIOHAL CONDITIONS as required to cOl'l_pJ,y wn~ AtTIUR regu remenb.**
4.0.. S Surveillance Requirements for inservice inspection and testing cf ASME Code Class 1. i. and 3 components shall be applicable as follo~s:
a. Inservice inspection of A...* Code Class l, 2. and 3 components and inservice testing of ASHe Code Class 1. 2, and 3 pumps and vahes shall be performed ff't accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as requtred by 10 CFR so. Section 50.55a(g), except where spectfic written relief has been granted by the Connission pursuant to 10 CFR 50, Section 50.55a{g)(6)(1). .
b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservic~
inspection and testing activities required by the ASME 8o11er and
TSTF-529, Rev. 3 19 APPUCAIILITY SURVEILLANCE REQQIREMEJn'S Pressure Yessel Code and applicable Addenda shall be applicable as follows fn these Tec~nical Specfficat1ons: ,
ASME Boiler and Pl"Usure Vessel Required frequencies Code and applfcab1e Addenda for performing 1nservfc:e terwfnology for 1nservfce fnspectfon and testing Jnseectton and testing tstfvt ties vf....t*fe..,s...___..._ ____
.,ac,,_t..,t....
Wie'1y At least once per 7 Cliys Monthly At least once per 31 days Quarterly or every 3 110nths At least once per 92 days S*1aMUally or e\'eey 6 months At. least once per 184 days
£very 9 11m1ths At least once per 276 days Yearly or annually At least once per 366 days
c. TM provfsfons of Specfffcatfon 4.0 .. t are applfcable to the above required frequenctes for performing f nserv1ce inspection and testing actf,itfes.
d. Perfonaance of the ai)ove 1nserv1ce tnspectfon and* testing ac:ttvitfes shall be fn addition to other spec1f1ed SUrve111ance Requt1"1!11lents.
e.. IOthfttg fn the ASME Bofler artd Pressure Vessel Coc:le sha11 be construed to supersede the reqa1,..nts R' any lechntcal Specification.
,,, :.A v
BWR STS 3/4.0-3
TSTF-529, Rev. 3 Enclosure 5 to Generic letter 81-09
s enc osure prov1des revised Bases for all specff1cat1ons 1n Stctfons 3.0 and 4.0.J .
BASES SPfif1cations 3.0.l through 3.0.4 *.stablish the general requirements applicable i04m1ting tondit~ons for Operatfon.. These requirements are based on the requirements for L1mftiflS Conditions for Operatfon stated in the Code of Federal Regulations, 10 CFR S0.36(c)(Z)! .
"L im1t1ng condition$ for operation are the lowest funct1ona1 capabiUty or performance levels of equipmtnt required for safe operation of the facility. When a limiting conditfon for operation of 1 nuclear reactor is not met, the 11ce'1see shell shut down the reactor or fallow any remedial ac:tion penrrttted by the technical specif1catfott untn the cond1t1on can be met ..
S!Sfiffcatfon 3.0.1 esta.hlfshes the Applfc1b1lfty statement within each fn Yldua1 s'pect¥fcat1on as the !"eq\11rement for when (1.e., fn tfh1ch OPERATIONAL COlfDITIOHS ot other spec1f1ed condft1ons) confor111nce to the Li*iting Concf1tions for Operation 1s ..equired for safe operation of the facility. The ACTION require111ents establish those remedial measures that must be taken within Sf.M!Cff1ed time 1fm1ts when the requirements of a l 1mit1ng Condition for Operation are not met.. It is not intended that the shutdown ACTION requirements be used as an operational conV1ftfence which penn1ts (routine) voluntar;r 'l'elllOYl1 of
system(s) or comrronent(s) .from service tn llet1 o'f other alternatives that would not result fn redundant systems or components being inoperable.
There are two basfc types of ACTION requirements. The first specifies the remedial 111easur111 that permit continued operation of the facility which is not further restricted by the time 11m1ts of the ACTION requirements. In this case, conformance to the.ACTION requirements provides 1n acceptable level of safety for unlimited continued operation as long as the ACTION requirements continue to be met. The second type of ACTION requiret:11nt specifies a time Hlfft in whfch conformance to the conditions of the l'fmit1ng Condition for Operation *st be met. This time 11m1t is the allowable outage time to restore an 1noperable system or camponent to OPERABLE status or for restorin9 parameters wfth1n spectfied limits. If these actions are not completed wtthtn the allowable outage time limits, a shutdown fs required to place the facility in an OPERATIONAL CONDITION or other specified condition in which the specification no longer applies.
The specified time limtts of the ACTION requirements are applfcible from the point in time it is identified that a limiting Cet,,ditton for Operation is not met. The time 11m1ts of the ACTION requirements are also applicable when a system or component is r11110ved from service for surveillance testing or investigation of operational problems. Ind1vfdual spec1f1cat1ons may include
a specified time limit for the completion of a Surveillance Requirement when BWR STS 8 3/4.0-1
TSTF-529, Rev. 3 Attachment 3 NRC Memorandum, "Summary of Meeting Held on September 17, 1987 Relating to Generic Letter 87-09," dated October 20, 1987
TSTF-529, Rev. 3 I
UNf1'1D fTATU NUCt..IAA RIGULATORV COMMISSION
.........~ O.C.JOMI OCT! O 1981 DOCY.ET MOS.: 50*325/324 & 50*400 LICS:NSH: Carolin& Power l Light Ccmp1rty FACILl TY : SMaron H4f"T"1 s
Un1t 1
.SUBJECT;
SUMMARY
OF M£!TlHG Htt.O OH $£PTOllD 17, l9e1 R£t.ATIRG TO GEH£RIC LETTER 87-09 A mtt1n9 was held with representatives of the CArc11nA Pcw*r & Light C=ciany (CP!L) in Stthe$d4, MD. en S*Ptembtr 11, 1987 to d1sc:uss Generic: Letter S7*1JP,
sect1ons 3.0 acrtd 4.0 of ttlt Standard Tuhn1cal Speci11cat1ons (ST'S) 011 tilt 1pplicibf1 ity o1 Limiting Conditions for Operation it'd Surveil1ance Rtqufr1tnents 11 dated Jun* 4. 1967. u ft rtlO.tt to - Shearon Harris Unit t and the Brunswick llnfts l & 2 nuch1r power pi&nu. A Htt c'f 1ttendets fs utachld.
C?tit. expressed 'oncerrt aboui the ~otenti a.1 f4r mi sinterprettt1 on of tht Sift tenet Wtdel'°H,utd below, fer MH of reference. and wtlidl ap~e*rs on page 8 314.0-1 of tnc1oture l to Gtneric L*t*r 17*49.
Tbtt ccncern OfntSStd is th&t it could PfQhitJi'C CJ'M. fJ"Cftl 9oin9 vatunur11~ fnto 1 Lfmit1ng Condit fen for 0pet"tt1on (LCD) fn ctrta1n just'fff1ol1 fnstancas. A1' example of such: an ins t1nc1 wou 1d ha if a sma 11 1uk devel op*d in a pwnp 1u 1 wlt'fc;tr 1n itself would not rendlr tn1 *P\lllf tno,.rao1t but !'fad th* pottnt111 for r1ndering tfte PWll9 fnoperabte at a f~tvrt date. CPlt. wouid lfka the option of voluntarily entering a LCO by isatatinf w pump and ai1n9 the t"tqu1nd f"IP*1~
without bef n9 c1te4 101' sucn action. Tht HIC su'ft' no.ud that t!'le underlined section of ih* 9ases for Spec1f1cat1art i.a.1. noted 1oove. would not &pp1y to the u*1* c1ied b)I CPIL s1nc1 it it net a use fn vh1dr l"edundant. s1sum ~ld f:HI aut af s*rv1c.. TH tt.lt'f nottd wt h1 add'ftton tc th* M be.sic typu o1 action ,...,,1rements that tn notad in the .saccnd paragn1)h of th* !Hts fol" S~1c1 t'tcat1o.n 3.0.1, .a thiYd type would de1'ine t1ow 11m1ts fer direc:t.ly pl acing the Dl1nt in 1 shutdown ;,cndft'fon. rt was noted that the sentence 1n question, ut1darHn1d 1.bau, that wu a ,c:onc*"' ta ~11. was intended to tpply ta thh type of shutdown ac:tian r~irerntnt. The staff noted Wt a similar s*ntenc1 is inc:ludtd in the Sues faf' Sp1c1f1c1t'fon 3.a.3.. In batlt eaus the f)oint of c1arif1caticn is ttrat the last *dt*lan o1 d1f1ns.a shou14 ttot be removed ft'T'Jll service sudl tnat t.nh would invoke a i:1rccnpt shutdown &Gt.ion requireant, 1n i,1eu o'f ether &lttl""na-tives that would not r.sutt fo red.ul'ldant systetns beinq out of Hl"'Yfc1 simultan1ous1 1
TSTF-529, Rev. 3
-~*
CP&l uk1d ff\r 11 clariflc1t.ion of whtf\ f\ 1Utued survtd11anctt h r"t!IJorttd under the ltn un~. Th.t ltdff ttattd thllt tt a Pllssed lurveillance h not 11ttrformud within t.he 1lC1w~ncn fnr *~Umd1no th'1 survei Uanet! 1nterva l t'lll providPd h1 5per."h.;altun 4.C\.:". t t WC\1 1ld htt reportablrc1 This is rl'nshtent with tho clarificatton of thl LEA A.uh thl\l h provided to NUft£G*lO~~. Supplenieol 11.
Cf.J&L ukod H thtNt WH Any sftJnHh.:nru*p bet.wneo lht words ft1lu1*e to il\llt" 11
,md the wtu*tl\ 11 nnnenm1,liance wHh'* which h rm*rcmt1y tn Spf!cification 4.0.3 of 1'ttnf1rir: h.it ter H1*U9. lhe ~tart 1ot.aled they b!'th menn th~ Sllllt And thct tt dot's nn t. 1lllpOM' any now ruqu I remunt.
lh1rt c. tiurk'py, Scmictt* Project MaMner flroJ(lt t ri1 n*. lorale l I* l Uivh hm of i:cnctor ProJ1ttts 1/1 t
TSTF-529, Rev. 3 Attachment 4 Inspection Manual Part 9900 Technical Guidance document, "Standard Technical Specifications (STS) Section 3.0.3 Limiting Conditions for Operation"
TSTF-529, Rev. 3 IJNrreo ST ATES ii*
NUCLEAR RIQULATORY COMMISSfON w~sMtNOTCH.o.e.21111t
NAC INSPECTION MANUAL
,ART ~9GO: TECMMICAI. GUlOAHC!
STAHOARD TtCHNlCAL. SPECl,lCATIOff.S STS SECTIOt4 3.0.3 LlM!TIHG tONtllT10MS FOR GPERATlQH A. PUAPOSi
a. SACXDOUKD R19.ion1 tU and V htvt r*oorted t.ht incon-tct use of the Jtr't1Ybians of STS Seci,on 3.C,~ b.y H~enues. As u 1ump11*. Tecttnic*l Specif1cat1on 3.7 ,A.S * .b fer. Dresden enc Qvad Cities. ind si111fl1r sp~if1cationa for other pitnts.
HtaoH sh .tbt con;aiment o>e)'gtn conc*ntrai;icn l"*air-.nts ovr1ng* th* %4 hcui-s P1'101" ic 4 shutdown, inca at."r the rttctor *ct* twitci1 hts betn p1u9d in th* nn l)oa1t.1on on sunui1. If the ox191n-111ow1ble =nct*tration ucaea ..
the ttc~nft*l spectf1~at1o~ 11Mit far mort tha" 24 ho111'"S prior to shutdown 01" *..*
for nrore than 2.4 ttours a1'ter th* reador med*. switch tt.t been plactd 1n ttte
r.m pos1iion on sta1'tu,, ttle plant 11 1n v1ut1t1on cf th* i..c;o *nd should be
.shut down 1n accordance With th* \.CQ.. HCMtv*r, th* Hein*** pf"opoaed 'to !'4 tfttar Leo 3.0.3 at the tmi of tn* 24-hour ptr1od trtd u11 ttte ~~uiremt"tl of
!..CO 3.0.3 to have an lddftion11 12 Spec1f1c;at1cm 3.7.A.i.J>, defints
"°""' conditions
~he two to shut down the plant. Ttc!'tn1eat for wh1ch oxnen concen-f tra.:1on can b* t1f.cted*d. Fo.,. eitbll" cand1t1ora, an explicit Z**hour t1me limit ~
for snut't1ng down 11 ptc"#ided. There 1r* no other c1r':\Ull$'ClnCH which art *.
not accoun'ted for, 1no STS 3.,0.3 dots not app11. i TM STS basic: 1nfo1'1M1:i10fl pPOv1dtd i~ .l191ons 3,0.~ 1* dltc11Htd lo tji* *~ion below.
UI and V c:onc:arning the uu of l
(
c. DtSCUSS1ot4 t.CO as dwf 1ntd in STS 3.0.3 is not it1tertded to be Hed 11 an opt1"at1ona 1 i
'f.
conven; enc;* wn 1en per111 t;s ncunctant n1'*t.Y sn~** tc b* out of serv1 ct for a t 1tndttd period of tia. l ta intended purpose it to PffY1de ptda$t on ta.
I.
time lidri'ts for 1n *oT'\:lwlt' shlfWown when the htciivioua 1 1..CO ar ACTlOK statttnafttt in otll*r t~1f1c:a't1ons cannot IM ntllCJHed with. Voluntary t1nt'l"Y 1nto LCO 3.Q.3 d*Hbrstely rotlllW*S 'th* l*tt li...- of d*f'*se *g11ns't pottnthllY h.armfu1 ev*nt.s. Dotnt to allows l"&IOVal of
sptat fT>om service wh* the 1"ttdr.&rtd*nt systa 1s 1 lf"eady tno~*r*b 11. An act11'n Hie* this snow a d1trtt*rd for p lint **'*'tY and is unaccept&b1e.,
"°"'
rt atso sbcl.l \d bt 14
has1xtd tlTat rU'IOv&1 of a $)"Jtlflf ~PVm strvice is jvstif1ed on1y for
'r:ast. 111.int*n*nce, or r*p*t"" puroous. 1 Issue Date: OS/31/87
TSTF-529, Rev. 3 Model Application for Adoption of TSTF-529
TSTF-529, Rev. 3
[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 Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules." 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, for information only, 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.
Page 1
TSTF-529, Rev. 3
[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 Page 2
TSTF-529, Rev. 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) to clarify the use and application of the TS usage rules, as described below:
Section 1.3 is revised to clarify "discovery."
Section 1.3 to revised to discuss exceptions to starting the Completion Time at condition entry.
Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.
Surveillance Requirement (SR) 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.
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 Page 3
TSTF-529, Rev. 3 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," that is an approved change to the standard technical specifications (STS), into the [PLANT NAME, UNIT NOS] technical specifications (TS). The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. 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. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.
[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:
1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes to 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 change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes 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 Page 4
TSTF-529, Rev. 3 requirements for plant systems or the actions taken when plant systems are not operable.
Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed is there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.
Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.
Based on the above, [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.
Page 5
TSTF-529, Rev. 3 Improved Technical Specifications Mark-Up
TSTF-529, Rev. 3 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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 Babcock & Wilcox STS 1.3-1 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 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.
Babcock & Wilcox STS 1.3-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:
a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,
b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and
c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (; exceptions to this Specification are stated in the individual Specifications);, or Babcock & Wilcox STS 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.
Babcock & Wilcox STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
Babcock & Wilcox STS B 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.2 (continued)
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. 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/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:
a. An associated Required Action and Completion Time is not met and no other Condition applies or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
Babcock & Wilcox STS B 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.3 (continued)
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
a. The LCO is now met,
b. The LCO is no longer applicable, bc. A Condition exists for which the Required Actions have now been performed, or cd. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering reaching the next lower MODE applies. If a lower MODE is reached entered in less time than allowed, however, the total allowable time to reach enter MODE 5, or other applicable MODE, is not reduced.
For example, if MODE 3 is reached entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time Babcock & Wilcox STS B 3.0-3 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 allowed for reaching entering MODE 4 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for reaching entering Babcock & Wilcox STS B 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.3 (continued)
MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach enter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Fuel Storage Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into 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 Babcock & Wilcox STS B 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 Required Actions followed after entry into the Applicability in accordance with the provisions of the Required Actions.
Babcock & Wilcox STS B 3.0-6 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.4 (continued)
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.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the Babcock & Wilcox STS B 3.0-7 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
Babcock & Wilcox STS B 3.0-8 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.4 (continued)
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. 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., RCS Specific Activity[Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.
Babcock & Wilcox STS B 3.0-9 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 BASES LCO 3.0.4 (continued)
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate either:
a. The OPERABILITY of the equipment being returned to service or
b. The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped Babcock & Wilcox STS B 3.0-10 Rev. 4.0
TSTF-529, Rev. 3 LCO APPLICABILITY B 3.0 channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment are is taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
Babcock & Wilcox STS B 3.0-11 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.1 (continued)
Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
Some examples of this process are:
a. Emergency feedwater (EFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi.
However, if other appropriate testing is satisfactorily completed, the EFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the EFW pump testing.
b. High pressure injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per ..." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
Babcock & Wilcox STS B 3.0-21 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.2 (continued)
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed performed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
Babcock & Wilcox STS B 3.0-22 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.3 (continued)
This delay period provides an adequate time to perform complete Surveillances that have been missed. This delay period permits the completion performance of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.
Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance Babcock & Wilcox STS B 3.0-23 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.
For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
This Regulatory Guide addresses consideration of temporary and Babcock & Wilcox STS B 3.0-24 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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 Westinghouse STS 1.3-1 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 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 Westinghouse STS 1.3-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:
a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,
b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and
c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications);, or Westinghouse STS 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.
Westinghouse STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
Westinghouse STS B 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.2 (continued)
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The 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/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
a. An associated Required Action and Completion Time is not met and no other Condition applies or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
Westinghouse STS B 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
a. The LCO is now met,
b. The LCO is no longer applicable, b.c. A Condition exists for which the Required Actions have now been performed, or c.d. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reachentering the next lower MODE applies. If a lower MODE is reachentered in less time than allowed, however, the total allowable time to reachenter MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reachentered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for Westinghouse STS B 3.0-3 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 reachentering MODE 4 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for reachentering Westinghouse STS B 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reachenter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.15, "Fuel Storage Pool Water Level." LCO 3.7.15 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.15 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.15 of "Suspend movement of irradiated fuel assemblies in the fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into 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 Westinghouse STS B 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 Required Actions followed after entry into the Applicabilityin accordance with the provisions of the Required Actions.
Westinghouse STS B 3.0-6 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
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.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the Westinghouse STS B 3.0-7 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
Westinghouse STS B 3.0-8 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. 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., RCS Specific Activity[Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.
Westinghouse STS B 3.0-9 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:
a. The OPERABILITY of the equipment being returned to service or
b. The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
Westinghouse STS B 3.0-10 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment areis taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
Westinghouse STS B 3.0-11 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.1 (continued)
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
Some examples of this process are:
a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi.
However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
b. High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per . . ." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the Westinghouse STS B 3.0-21 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.2 (continued) 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations. As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed performed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to perform complete Surveillances that have been missed. This delay period permits the performance completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
Westinghouse STS B 3.0-22 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.3 (continued)
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.
Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.
For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly 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 Westinghouse STS B 3.0-23 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensees Corrective Action Program.
Westinghouse STS B 3.0-24 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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 Combustion Engineering STS 1.3-1 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 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.
Combustion Engineering STS 1.3-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:
a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,
b. [MODE 4 within 13] hours, and
c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications);, or
c. When an allowance is stated in the individual value, parameter, or other Specification.
Combustion Engineering STS 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
Combustion Engineering STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
Combustion Engineering STS B 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.2 (continued)
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The 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/trains of a safety function are inoperable and limits the time conditions exist which may result in LCO 3.0.3 being entered. Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and either:
a. An associated Required Action and Completion Time is not met and no other Condition applies or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
Combustion Engineering STS B 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
a. The LCO is now met,
b. The LCO is no longer applicable, cb. A Condition exists for which the Required Actions have now been performed, or dc. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reachentering the next lower MODE applies. If a lower MODE is reachentered in less time than allowed, however, the total allowable time to reachenter Combustion Engineering STS B 3.0-3 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reachentered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reachentering MODE 4 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for reachentering MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reachenter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.16, "Fuel Storage Pool Water Level." LCO 3.7.16 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.16 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.16 of "Suspend movement of irradiated fuel assemblies in fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
[ The requirement to be in MODE 4 in 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months is plant specific and depends on the ability to cool the pressurizer and degas. ]
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
Combustion Engineering STS B 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
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 Applicabilityin accordance with the provisions of the Required Actions.
For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified 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.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Combustion Engineering STS B 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
Combustion Engineering STS B 3.0-6 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. 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., RCS Specific Activity[Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
Combustion Engineering STS B 3.0-7 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate either:
a. The OPERABILITY of the equipment being returned to service or
b. The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
Combustion Engineering STS B 3.0-8 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.5 (continued)
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment areis taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions.
Combustion Engineering STS B 3.0-9 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.1 (continued)
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
Some examples of this process are:
a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi.
However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
Combustion Engineering STS B 3.0-19 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.2 (continued)
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to perform complete Surveillances that have been missed. This delay period permits the performance completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion performance of the Surveillance.
Combustion Engineering STS B 3.0-20 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.3 (continued)
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.
Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.
For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail Combustion Engineering STS B 3.0-21 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 to allow a knowledgeable individual to understand the basis for the determination.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant Combustion Engineering STS B 3.0-22 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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 General Electric BWR/4 STS 1.3-1 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, 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 division, 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.
General Electric BWR/4 STS 1.3-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:
a. MODE 2 within [7] hours,
b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and
c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

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

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; General Electric BWR/4 STS 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 LCO Applicability LCO 3.0.4 (continued)
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications);, or
c. When an allowance is stated in the individual value, parameter, or other Specification.
This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met.
When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.
General Electric BWR/4 STS 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.
General Electric BWR/4 STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
General Electric BWR/4 STS B 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.2 (continued)
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.10, "RCS Pressure and Temperature (P/T) Limits."
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The 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.
Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
a. An associated Required Action and Completion Time is not met and no other Condition applies or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
General Electric BWR/4 STS B 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
a. The LCO is now met,
b. The LCO is no longer applicable, cb. A Condition exists for which the Required Actions have now been performed, or dc. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reachentering the next lower MODE applies. If a lower MODE is reachentered in less time than allowed, however, the total allowable time to reachenter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is reachentered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reachentering MODE 3 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for General Electric BWR/4 STS B 3.0-3 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 reachentering MODE 3 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 General Electric BWR/4 STS B 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reachenter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.8, "Spent Fuel Storage Pool Water Level." LCO 3.7.8 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into 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 Applicabilityin accordance with the provisions of the Required Actions.
General Electric BWR/4 STS B 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION ("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the General Electric BWR/4 STS B 3.0-6 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
General Electric BWR/4 STS B 3.0-7 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. 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., RCS Specific Activity[Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.
General Electric BWR/4 STS B 3.0-8 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 AND LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specifications.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:
a. The OPERABILITY of the equipment being returned to service or
b. The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
General Electric BWR/4 STS B 3.0-9 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment areis taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
General Electric BWR/4 STS B 3.0-10 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.1 (continued)
Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
Some examples of this process are:
a. Control Rod Drive maintenance during refueling that requires scram testing at > [800 psi]. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach [800 psi] to perform other necessary testing.
b. High pressure coolant injection (HPCI) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPCI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
General Electric BWR/4 STS B 3.0-20 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.2 (continued)
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Primary Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
General Electric BWR/4 STS B 3.0-21 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.3 (continued)
This delay period provides adequate time to complete perform Surveillances that have been missed. This delay period permits the performance completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.
Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance General Electric BWR/4 STS B 3.0-22 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.
For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
This Regulatory Guide addresses consideration of temporary and General Electric BWR/4 STS B 3.0-23 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).
DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.
Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action 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 General Electric BWR/6 STS 1.3-1 Rev. 4.0
TSTF-529, Rev. 3 Completion Times 1.3 discovery of the situation that required entry into the Condition, unless otherwise specified.
Once a Condition has been entered, subsequent divisions, 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 division, 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.
General Electric BWR/6 STS 1.3-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:
a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,
b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and
c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications);, or
c. When an allowance is stated in the individual value, parameter, or other Specification.
General Electric BWR/6 STS 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.
General Electric BWR/6 STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 General Electric BWR/6 STS 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability 3.0 SR Applicability SR 3.0.4 (continued)
This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
General Electric BWR/6 STS 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:
a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification and
b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.
Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
General Electric BWR/6 STS B 3.0-1 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.2 (continued)
The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no longer exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.11, "RCS Pressure and Temperature (P/T) Limits."
The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The 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.
Individual Specifications may specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.
When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition(s) are entered.
LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:
a. An associated Required Action and Completion Time is not met and no other Condition applies or
b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.
General Electric BWR/6 STS B 3.0-2 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter 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 capabilities of the unit, assuming that only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
a. The LCO is now met,
b. The LCO is no longer applicable, cb. A Condition exists for which the Required Actions have now been performed, or dc. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for reachentering the next lower MODE applies. If a lower MODE is reachentered in less time than allowed, however, the total allowable time to reachenter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 2 is reachentered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then the time allowed for reachentering MODE 3 is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , because the total time for General Electric BWR/6 STS B 3.0-3 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 reachentering MODE 3 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 General Electric BWR/6 STS B 3.0-4 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reachenter a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, "Fuel Pool Water Level." LCO 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the associated fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into 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 Applicabilityin accordance with the provisions of the Required Actions.
General Electric BWR/6 STS B 3.0-5 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
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.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the General Electric BWR/6 STS B 3.0-6 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
General Electric BWR/6 STS B 3.0-7 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. 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., [RCS Specific ActivityContainment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.
General Electric BWR/6 STS B 3.0-8 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:
a. The OPERABILITY of the equipment being returned to service or
b. The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.
An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.
General Electric BWR/6 STS B 3.0-9 Rev. 4.0
TSTF-529, Rev. 3 LCO Applicability B 3.0 Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment areis taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2). A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.
The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.
General Electric BWR/6 STS B 3.0-10 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.1 (continued)
Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed. Some examples of this process are:
a. Control Rod Drive maintenance during refueling that requires scram testing at > [800 psi]. However, if other appropriate testing is satisfactorily completed and the scram time testing of SR 3.1.4.3 is satisfied, the control rod can be considered OPERABLE. This allows startup to proceed to reach [800 psi] to perform other necessary testing.
b. Reactor Core Isolation Cooling (RCIC) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with RCIC considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
General Electric BWR/6 STS B 3.0-20 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.2 (continued)
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. An example of where SR 3.0.2 does not apply is in the Primary Containment Leakage Rate Testing Program. This program establishes testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot in and of themselves extend a test interval specified in the regulations.
As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
General Electric BWR/6 STS B 3.0-21 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 BASES SR 3.0.3 (continued)
This delay period provides adequate time to perform complete Surveillances that have been missed. This delay period permits the performance completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.
However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed.
Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed.
General Electric BWR/6 STS B 3.0-22 Rev. 4.0
TSTF-529, Rev. 3 SR Applicability B 3.0 For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.
This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action General Electric BWR/6 STS B 3.0-23 Rev. 4.0

v t e Letter Sequence Request
TAC:MF1406, Clarify Use and Application Rules (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions 2 June 2015 Answers Results Approval, Approval Other:
MONTHYEAR2015-06-02 [Table View]

TSTF-15-08, Technical Specifications Task Force - Transmittal of TSTF-529, Revision 3, Clarify Use and Application Rules.

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TSTF-15-08, Technical Specifications Task Force - Transmittal of TSTF-529, Revision 3, Clarify Use and Application Rules.

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