View source for PLA-5901, Proposed Amendment No. 276 to License NPF-14 and Proposed Amendment No. 245 to License NPF-22: Application for Technical Specification Improvement to Revise Technical Specifications to Add Limiting Conditioner for Operations 3.0.8..

{{Adams
| number = ML060410106
| issue date = 02/01/2006
| title = Proposed Amendment No. 276 to License NPF-14 and Proposed Amendment No. 245 to License NPF-22: Application for Technical Specification Improvement to Revise Technical Specifications to Add Limiting Conditioner for Operations 3.0.8..
| author name = Mckinney B
| author affiliation = PPL Susquehanna, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000387, 05000388
| license number = NPF-014, NPF-022
| contact person = 
| case reference number = PLA-5901
| document type = Letter type:PLA, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 19
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Dritt T. McKlnney Sr. Vice President & Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 I
Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com                      % TMI FEB 0 1 2006 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NO. 276 TO LICENSE NPF-14 AND PROPOSED AMENDMENT NO. 245 TO LICENSE NPF-22: APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO REVISE TECHNICAL SPECIFICATIONS TO ADD A LIMITING CONDITION FOR OPERATION 3.0.8 ON INOPERABILITY OF SNUBBERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS                                                               Docket Nos. 50-387 PLA-5901                                                                                      and 50-388 In accordance with the provisions of 10 CFR 50.90, PPL Susquehanna, LLC is submitting a request for an amendment to the Technical Specifications (TS) for Susquehanna Units 1 and 2.
The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.
These proposed changes have been reviewed by both the Plant Operations Review Committee and the Susquehanna Review Committee. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing Technical Specification pages marked-up to show the proposed change. Attachment 3 provides the TS Bases pages marked-up to show the proposed changes for information. Attachment 4 provides the list of regulatory commitments.
Abelf

Document Control Desk PLA-5901 PPL Susquehanna, LLC requests approval of the proposed License Amendment by May 1, 2006 with the amendment, and regulatory commitments, being implemented within 60 days following approval.
In accordance with 10 CFR 50.91(b), PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.
If you have any questions regarding this submittal, please contact Mr. Cornelius T. Coddington at (610) 774-4019.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:   _     _1__0__
B. T. McKinney Attachments:
Attachment 1 - Description, Applicability, and Verification of the Proposed Change Attachment 2 - Proposed Technical Specification Changes Units 1 & 2, (Mark-ups)
Attachment 3 - Technical Specification Bases "Markup" Pages (Provided for Information)
Attachment 4 - List of Regulatory Commitments cc:    NRC Region I Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP

Attachment; 1 to PLA-5901 Description, Applicability, and Verification of the Proposed Change

Attachment I to PLA-5901 Page 1 of 2 I                      DESCRIPTION AND ASSESSMENT                                              I

==1.0    DESCRIPTION==

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding LCO 3.0.8.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-372, Revision 4. The availability of this TS improvement was published in the FederalRegister on May 4, 2005 (70 FR 23252) as part of the consolidated line item improvement process (CLIIP).
2.0    ASSESSMENT 2.1    Applicability of Published Safety Evaluation PPL Susquehanna, LLC has reviewed the safety evaluation dated May 4, 2005 (70 FR 23252) as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-372. PPL Susquehanna, LLC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Susquehanna Steam Electric Station, Unit 1 and Unit 2 and justify this amendment for the incorporation of the changes to the Susquehanna Steam Electric Station, Unit 1 and Unit 2 TS.
2.2    Optional Changes and Variations PPL Susquehanna, LLC is not proposing any variations or deviations from the TS changes described in the TSTF-372 Revision 4 or the NRC staff's model safety evaluation dated May 4, 2005 (70 FR 23252).

==3.0    REGULATORY ANALYSIS==

3.1    No Significant Hazards Consideration Determination PPL Susquehanna, LLC has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLIIP. PPL Susquehanna, LLC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Susquehanna Steam Electric Station, Unit 1 and Unit 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Attachment 1 to PLA-5901 Page 2 of 2 3.2     Verifications And Commitments As discussed in the model SE published in the Federal Register on May 4, 2005 (70 FR 23252) for this TS improvement, plant-specific verifications were performed as follows:
PPL Susquehanna, LLC will establish TS Bases for LCO 3.0.8, which provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases will also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
Additionally, Susquehanna Steam Electric Station Unit 1 and Unit 2 currently have a Bases Control Program consistent with Section 5.5 of the STS.
4.0 ENVIRONMENTAL EVALUATION PPL Susquehanna, LLC has reviewed the environmental evaluation included in the model safety evaluation published on May 4, 2005 (70 FR 23252) as part of the CLIIP. PPL Susquehanna, LLC has concluded that the staff's findings presented in that evaluation are applicable to Susquehanna Steam Electric Station and the evaluation is hereby incorporated by reference for this application.

Attachment 2 to PLA-5901 Proposed Technical Specification Changes Units 1 & 2 (Mark-ups)

PPLRev.4 l 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 3.0.2k an4-LCO 3.0.7 and LCO 3.0.8.
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 hour to place the unit, as applicable, in:
: a.       MODE 2 within 7 hours;
: b.       MODE 3 within 13 hours; and
: c.       MODE 4 within 37 hours.
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.
(continued)
SUSQUEHANNA - UNIT 1                TS / 3.0-1                         Amendment 18, ~/9

PPL Rev. 4 1 LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.6              program, the appropriate Conditions and Required Actions of the (continued)           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.
LCO 3.0.8              When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:
: a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours: or
: b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours.
At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected suDoorted system LCO(s) shall be declared not met.
* X *                    ..   .. .
(continued)
SUSQUEHANNA - UNIT 1               TS /3.0-3                               Amendment 1Ai8,24      l

PPLRev.4 l LCO Applicability 3.0 3.0 LIMITING CONDITIONS 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 3.0.2k aPA-LCO 3.0.7 and LCO 3.0.8.
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 hour to place the unit, as applicable, in:
: a.       MODE 2 within 7 hours;
: b.       MODE 3 within 13 hours; and
: c.       MODE 4 within 37 hours.
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.
(continued)
SUSQUEHANNA - UNIT 2                T S / 3.0-1                          Amendment I di,     ;96

PPLRev.4 l LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.6             program, the appropriate Conditions and Required Actions of the (continued)         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.
LCO 3.0.8            When one or more required snubbers are unable to perform their associated support function(s). any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:
: a. the snubbers not able to Derform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem surmorted system and are able to perforn their associated support function within 72 hours' or
: b. the snubbers not able to perform their associated-support function(s) are associated with more than one train or subsystem of a multiple train or subsystem -suvported system and are able to perform their associated support function within 12 hours.
At the end of the specified period the required snubbers must be-able to perform their associated support function(s). or the affected supported system LCO(s) shall be declared not met.
SUSQUEHANNA - UNIT 2              TS /3.0-3                              Amendment Al, l-5

Attachment, 3 to PLA-5901 Technical Specification Bases "Markup" Pages (Provided for Information)

PPL Rev. 4 l LCO APPLICABILITY B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs              LCO 3.0.1 through LCO 3.08 3.0.74establish the general requirements                I applicable to all Specifications and apply at all times, unless otherwise stated.
LCO 3.0.1         LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e.,
when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2         LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that 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 (continued)
SUSQUEHANNA - UNIT I                    B 3.0-1                                         Revisionle

PPLRev.4 l LCO APPLICABILITY B 3.0 BASES LCO 3.0.7     The Applicability of a Special Operations LCO represents a condition not (continued)  necessarily in compliance with the normal requirements of the TS.
Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCOs Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCOs requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
LCO 3.0.8     LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers 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 performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance. testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures of TRO 3.7.8 are followed. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii). and.
as such, are approDliate for control within the Technical Requirements Manual.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.
I (continued)
SUSQUEHANNA - UNIT 1             TS / B 3.0-1 1                                   Revision 4    1

PPL Rev. 4 l LCO APPLICABILITY B 3.0 BASES LCO 3.0.8     LCO 3.0.8.a applies when one or more snubbers are not capable of (continued)  providing their associated support function(s) to a single train 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 hours to restore the snubber(s) before declaring the supported system inoperable. The 72 hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the suDported system.
LCO 3.0.8.b applies when one or more snubbers are not capable of 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 hours to restore the snubber(s) before declaring the supported system inoperable. The 12 hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated 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 maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is Properly controlled, and emergent issues are Properly addressed. The risk assessment need not be quantified. but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated suooort function.
                                                                                                ,1 SUSQUEHANNA - UNIT 1             TS / B 3.0-1 la                                    Revision 0  1

PPL Rev. 4 l 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 3.0.7 establish the general requirements              I applicable to all Specifications and apply at all times', unless otherwise stated.
LCO 3.0.1        LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e.,
when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2        LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that 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 (continued)
SUSQUEHANNA - UNIT 2                TS / B 3.0-1                                       RevisionX

PPL Rev. 4 l LCO Applicability B 3.0 BASES LCO 3.0.7      The Applicability of a Special Operations LCO represents a condition not (continued)   necessarily in compliance with the normal requirements of the TS.
Compliance with Special Operations LCOs is optional. A special operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO ACTIONS may direct the other LCOs' ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
LCO 3.0.8      LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers 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 performing their associated support function(s). This is appropriate because a limited lenath of time is allowed for maintenance. testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures of TRO 3.7.8 are followed. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii). and, as such, are appropriate for control within the Technical Requirements Manual.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s). the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with L.CO 3.0.2.
(continued)    I SUSQUEHANNA - UNIT 2             TS / B 3.0-1 1                                    Revision 4 l

PPLRev.4 l LCO Applicability B 3.0 BASES LCO 3.0.8      LCO 3.0.8.a applies when one or more snubbers are not capable of (continued)  providing their associated support function(s) to a single train 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 hours to restore the snubber(s) before declaring the supported system inoperable. The 72 hour Completion Time is reasonable based on the low Probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable 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 of 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 hours to restore the snubber(s) before declaring the supported system inoperable. The 12 hour Completion Time is reasonable based on the low Probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated 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 maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled. and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of svstems and components when one or more snubbers are not ahib  to nprform their assocriated q innort fiinrction SUSQUEHANNA - UNIT 2             TS / B3.0-1 la                                    Revision 0  l

Attachment; 4 to PLA-5901 List of Regulatory Commitments

LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by PPL in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
REGULATORY COMMITMENTS                                    DuelDate/Event
: 1. PPL Susquehanna, LLC will establish TS Bases for        Prior to implementation of LCO 3.0.8, which provide guidance and details on        approved Technical how to implement the new requirements.                  Specification amendment LCO 3.0.8 requires that risk be managed and assessed. The Bases will also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.}}