ULNRC-06686, Attachment 4: Proposed Technical Specifications Bases Changes (Mark-Up)

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Attachment 4: Proposed Technical Specifications Bases Changes (Mark-Up)
ML21343A098
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/09/2021
From:
Ameren Missouri, Union Electric Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML21343A092 List:
References
ULNRC-06686
Download: ML21343A098 (21)
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Text

Ameren Missouri (Union Electric Company)

Callaway Plant

Proposed Technical Specifications Bases Changes (Mark-Up)

CHAPTER TABLE OF CONTENTS

CHAPTER B 3.0

SAFETY LIMITS (SLs)

Section Page

B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY........................ B 3.0-1

LCOs.......................................................................................................... B 3.0-1 LCO 3.0.1................................................................................................... B 3.0-1 LCO 3.0.2................................................................................................... B 3.0-1 LCO 3.0.3.................................................................................................. B 3.0-2 LCO 3.0.4.................................................................................................. B 3.0-4 LCO 3.0.5.................................................................................................. B 3.0-7 LCO 3.0.6.................................................................................................. B 3.0-8 LCO 3.0.7.................................................................................................. B 3.0-9 LCO 3.0.8.................................................................................................. B 3.0-9

B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY..................................... B 3.0-11

SRs........................................................................................................... B 3.0-11 SR 3.0.1.................................................................................................. B 3.0-11 SR 3.0.2.................................................................................................. B 3.0-12 SR 3.0.3.................................................................................................. B 3.0-13 SR 3.0.4.................................................................................................. B 3.0-15

CALLAWAY PLANT 3.0-i LCO Applicability B 3.0

B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

BASES

LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

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

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that 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; a nd
b. Completion of the Required Actions is not required when an LC O 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 lim its. 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. (Wheth er stated as a Required Action or not, correction of the entered Condition i s an action that may always be considered upon entering ACTIONS.) The seco nd 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.

(continued)

CALLAWAY PLANT B 3.0-1 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.2 Completing the Required Actions is not required when an LCO is met or is (continued) no longer applicable, unless otherwise stated in the individua l Specifications.

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 applicabl e when a system or component is removed from service intentionally. T he reasons for intentionally relying on the ACTIONS include, but a re not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or invest igation of operational problems.

Entering ACTIONS for these reasons must be done in a manner tha t does not compromise safety. Intentiona l 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 limit s 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 whe n 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 othe r specified condition in which another Specification becomes appl icable. In this case, the Completion Times of the associated Required Acti ons 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

(continued)

CALLAWAY PLANT B 3.0-2 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.3 b. The condition of the unit is not specifically addressed by th e (continued) 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. So metimes, possible combinations of Conditions are such that enter ing LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the u nit in a safe MODE or other specified condition when operation cannot be main tained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational conve nience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that woul d not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 electrica l generation with the load dispatcher to ensure the stability and availabili ty of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and or derly manner that is well within the specified maximum cooldown rate and within the capabilities of the uni t, 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 w hich 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. A Condition exists for which the Required Actions have now be en performed.
c. ACTIONS exist that do not have expired Completion Times.

These Completion Times are applicable from the point in time th at the Condition is initially entered and not from the time LCO 3.0.3 is exited.

(continued)

CALLAWAY PLANT B 3.0-3 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.3 The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 (continued) 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 l imit for reaching the next lower MODE applies. If a lower MODE is reach ed in less time than allowed, however, the total allowable time to re ach MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reaching MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for reaching MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a p enalty is not incurred by having to reach 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 re strictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unles s 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 e x a m p l e 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 assembl ies in the fuel storage pool." Therefore, this LCO can be applicable in a ny or all MODES. If the LCO and the Required Actions of LCO 3.7.15 are not met while in MODE 1, 2, 3, or 4, there is no safety benefit to be gai ned 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 comple te 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 me t. 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 LCO 3.0.4.a, or 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 m et when the associated ACTIONS to be entered permit continued operation in the MODE or other specifi ed condition in the Applicability for an unlimited period of time. Compliance (continued)

CALLAWAY PLANT B 3.0-4 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.4 with Required Actions that permit continued operation of the unit for an (continued) 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 chang e.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisi ons of the Required Actions.

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 MOD E or other specified condition in the Applicability, and establishment of risk management actions, if applicable.

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 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 Regulat ory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 en dorses 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 ris k assessment, quantitative and qualitative guidelines for establi shing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manne r that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, act ions to minimize the magnitude of risk increases (establishment of back up 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 th e 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 deter mining the acceptability of entering the MODE or other specified condition in the (continued)

CALLAWAY PLANT B 3.0-5 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.4 Applicability, and any corresponding risk management actions. The (continued) LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equ ipment 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 appl icable 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 determi ned to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components con tain 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 speci fied 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., Cont ainment Air Temperature, Containment Pressure, 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 shutdow n 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, MODE 4 to MODE 5, and MODE 5 to MODE 6.

(continued)

CALLAWAY PLANT B 3.0-6 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.4 Upon entry into a MODE or other specified condition in the (continued) 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 C ondition 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 ino perable equipment (or on variables outside the specified limits), as pe rmitted 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 OPERABL E (or variable within limits) and restoring compliance with the a ffected 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 ser vice or declared inoperable to comply with ACTIONS. The sole purpose o f 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.

LCO 3.0.5 allows Required Actions to not be followed temporarily in order to demonstrate an LCO is met without exiting the Applicability of the Technical Specification.

The Administrative controls ensure the time the Required Action s are not met 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 preventative or corrective maintenance. LCO 3.0.5 should not be used in lieu of other practical alternative s that comply with ACTIONS or other Technical Specification allowances.

An example of demonstrating the OPERABILITY of the equipment be ing returned to service is opening (and re-energizing if de-activat ed) an inoperable automatic valve, that had been closed to comply with a Required Action, for the purpose of performing actuation or stroke time testing (e.g., any of the various valves covered by TS 3.7.2, MSIVs, MSIVBVs, and MSLPDIVs, or TS 3.7.3, MFIVs, MFRVs, and MFRVBVs).

(continued)

CALLAWAY PLANT B 3.0-7 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.5 An example of demonstrating the OPERABILITY of other equipment is (continued) reopening a pressurizer PORV block valve that has been closed to comply with Required Action A.1 of TS 3.4.11, Pressurizer Power Operated Relief Valves (PORVs), in order to confirm that the associated pressu rizer PORV no longer has excessive seat leakage. A similar example i s the reopening of a valve that was closed to comply with Required Action A.1 of TS 3.4.14, RCS Pressure Isolation Valve (PIV) Leakage, in order to perform testing to demonstrate that the RCS PIV leakage is now within limit.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). Th is 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 su pport system. This exception is justified because the actions that a re 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 sy stem's Conditions and Required Actions or may specify other Required Actions.

When a support system is inoperable and there is an LCO specifi ed for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support syste m inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multipl e support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported sy stem. This may occur immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate o r after some delay, when a support system's Required Action directs a s upported system to be declared inoperable or directs entry into Conditio ns and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.15, "Safety Function Determination Program (SFDP),"

ensures loss of safety function is detected and appropriate act ions are (continued)

CALLAWAY PLANT B 3.0-8 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.6 taken. Upon entry into LCO 3.0.6, an evaluation shall be made to (continued) determine if loss of safety function exists. Additionally, oth er limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Cross train checks to identify a loss of safety function for those support systems that support multiple and redundant safety systems are required.

The cross train check verifies that the supported systems of th e redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. If this evaluation determines that a los s of safety function exists, the appropriate Conditions and Required Action s of the LCO in which the loss of safety function exists are required to be entered.

LCO 3.0.7 There are certain special tests and operations requ ired to be performed at various times over the life of the unit. These special tests a nd operations are necessary to demonstrate select unit performance characteri stics, to perform special maintenance activities, and to perform special evolutions.

Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performances of these spec ial tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise spe cified, all the other TS requirements remain unchanged. This will ensure a ll appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform t he special test or operation will remain in effect.

The Applicability of a Test Exception LCO represents a conditio n not necessarily in compliance with the normal requirements of the TS.

Compliance with a Test Exception LCO is optional. A special op eration may be performed either under the provisions of the Test Exception LCO or under the other applicable TS requirements. If it is desire d to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

LCO 3.0.8 LCO 3.0.8 establishes conditions under which system s are considered to remain capable of performing their intended safety function whe n associated snubbers (i.e. snubbers designed for seismic loading or for seismic and dynamic loading where the seismic loading bounds th e dynamic loading), are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of (continued)

CALLAWAY PLANT B 3.0-9 Revision 16 LCO Applicability B 3.0

BASES

LCO 3.0.8 performing their associated support function(s). This is appro priate (continued) because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated suport function(s) and appropriate compensatory measures are identified and implemented to manage risk under licensee control.

Snubber requirements do not meet the criteria in 10 CFR 50.36(c )(2)(ii),

and, as such, are appropriate for control by the licensee.

If the allowed time expires and the snubber(s) are unable to pe rform their associated support function(s), the affected supported systems LCO(s) must be declared not met and the Conditions and Required Action s entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable o f providing their associated support function(s) to a single trai n or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hou rs to restore the snubber(s) before declaring the supported system inoperable.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low prob ability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not cap able of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable o f providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event conc urrent with an event that would require operation of the supported system o ccurring while the snubber(s) are not capable of performing their associ ated support function.

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintena nce activities, and integrated into the existing Maintenance Rule p rocess to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addres sed. The risk assessment need not be quantified, but may be a qualitativ e awareness of the vulnerability of systems and components when o ne or more snubbers are not able to perform their associated support function.

CALLAWAY PLANT B 3.0-10 Revision 16 SR Applicability B 3.0

B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY

BASES

SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.2 and SR 3.0.3 apply in Chapter 5 only when invoked by a Chapter 5 Specification.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveilla nces are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, h owever, is to be construed as implying that systems or components are OPER ABLE when:

a. The systems or components are known to be inoperable, althoug h still meeting the SRs; or
b. The requirements of the Surveillance(s) are known not to be m et between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a test exception are only applicable when the test excepti on is used as an allowable exception to the requirements of a Specificatio n.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose perform ance is normally precluded in a given MODE or other specified condition.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the

(continued)

CALLAWAY PLANT B 3.0-11 Revision 16 SR Applicability B 3.0

BASES

SR 3.0.1 ACTIONS define the remedial measures that apply. Surveillances have to (continued) 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 te sting is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent p erformance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in t he Applicability due to the necessary unit parameters not having b een 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 operatio n to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Comp letion Time that requires the periodic performance of the Required Act ion 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).

When a Section 5.5, "Programs and Manuals," specification states that the provisions of SR 3.0.2 are applicable, a 25% extension of the testing interval, whether stated in the Specification or incorporated b y reference, is permitted.

The 25% extension does not significantly degrade the reliabilit y that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of an y 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 n ot apply.

These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Therefore, when a test interval is specified in the regulations directly o r by reference, the test interval cannot be extended by the TS. Examples of wh ere

(continued)

CALLAWAY PLANT B 3.0-12 Revision 16 SR Applicability B 3.0

BASES

SR 3.0.2 SR 3.0.2 does not apply are the Containment Leakage Rate Testing (continued) Program (Section 5.5.16 ) as required by 10 CFR 50, Appendix J, and the testing of pumps and valves in the INSERVICE TESTING PROGRAM established per the American Society of Mechanical Engineers Operations and Maintenance (OM) Code, as required by 10 CFR 50.55a.

Extensions of test intervals under these programs are only as allowed by the programs and their regulations and not by any provisions in the Technical Specifications.

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 r emedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Ti me is that such an action usually verifies that no loss of function has oc curred by checking the status of redundant or diverse components or accom plishes the function of the inoperable equipment in an alternative mann er.

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 equipm ent inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Freque ncy, including the allowance of SR 3.0.2 as applicable. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whicheve r 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.

These provisions also apply to testing requirements in Section 5.5, Programs and Manuals. In such cases, when the Section 5.5 Specification states that the provisions of SR 3.0.3 are applicable, the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval, including the allowance of SR 3.0.2 (if invoked by the Section 5.5 Specification), similarly applies.

(continued)

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SR 3.0.3 The allowed delay period provides adequate time to complete (continued) Surveillances that have been missed. The delay period permits the completion of a Surveillance before complying with Required Act ions or other remedial measures that might preclude 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 probab le 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., pri or to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discov ered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specif ied Frequency to perform the Surveillance.

However, since there is not a time interval specified, the miss ed Surveillance should be performed at the first reasonable opport unity.

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.

Failure to comply with specified Frequencies for SRs is expecte d to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operationa l convenience to extend Surveillance intervals. While up to 24 h ours 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 impa ct 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 additi on to unit conditions, planning, availability of personnel, and the time r equired 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 (continued)

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SR 3.0.3 shutdown. The missed Surveillance should be treated as an emergent (continued) condition as discussed in the Regulatory Guide. The risk evalu ation 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 evaluat ion determine the risk increase is significant, this evaluation should be use d to determine the safest course of action. All missed Surveillance will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required A ctions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay per iod, then the equipment is inoperable, or the variable is outside the specifi ed limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillan ce.

Satisfactory completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACT IONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Ap plicability.

This Specification ensures that system and component OPERABILIT Y requirements and variable limits are met before entry into MODE S or other specified conditions in the Applicability for which these syste ms and components ensure safe operation of the unit.

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.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Su rveillances not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will n ot result in SR 3.0.4 restricting a MODE change or other specified condition change.

When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s ) are not required to be performed, per SR 3.0.1, which states that surveillances do

(continued)

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SR 3.0.4 not have to be performed on inoperable equipment. When equipme nt is (continued) inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefor e, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Ap plicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 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 SR 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 shutdow n 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, MODE 4 to MODE 5, and MODE 5 to MODE 6.

The precise requirements for performance of SRs are specified s uch that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency spec ified such that it is not "due" until the specific conditions needed are m et. Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

CALLAWAY PLANT B 3.0-16 Revision 16

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