ML18150A482

NRR E-mail Capture - (External_Sender) LCO 3.0.6 LAR Pre-submittal Call

ML18150A482
Person / Time
Site:	Saint Lucie, Seabrook, Turkey Point
Issue date:	04/23/2018
From:	Kilby G Florida Power & Light Co
To:	Justin Poole Plant Licensing Branch 1
References
L-2018-LRM-0027
Download: ML18150A482 (12)

Text

NRR-DMPSPEm Resource From: Kilby, Gary <Gary.Kilby@fpl.com>

Sent: Monday, April 23, 2018 1:45 PM To: Poole, Justin Cc: Catron, Steve

Subject:

[External_Sender] LCO 3.0.6 LAR Pre-submittal Call Attachments: Example Markups and Table LAR LCO 3-0-6.pdf Justin:

Attached are some draft example mark-ups of the technical specifications to support tomorrows call regarding the LAR to adopt LCO 3.0.6.

GLK 1

Hearing Identifier: NRR_DMPS Email Number: 391 Mail Envelope Properties (384fe12b46184348a3d99d0e7e40803f)

Subject:

[External_Sender] LCO 3.0.6 LAR Pre-submittal Call Sent Date: 4/23/2018 1:45:26 PM Received Date: 4/23/2018 1:46:16 PM From: Kilby, Gary Created By: Gary.Kilby@fpl.com Recipients:

"Catron, Steve" <Steve.Catron@fpl.com>

Tracking Status: None "Poole, Justin" <Justin.Poole@nrc.gov>

Tracking Status: None Post Office: fpl.com Files Size Date & Time MESSAGE 157 4/23/2018 1:46:16 PM Example Markups and Table LAR LCO 3-0-6.pdf 1223340 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION SBK INSERT APPLICABILITY 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in Specification 3.0.5.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Specification 3.0.5. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except ex as a provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action on shall be initiated in to place the unit in a MODE in which the specification does not apply by placing it, as applicable, a

appli in:

a. At least HOT STANDBY within the he T e next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, ho b.

c.

AF At least HOT SHUTDOWN within the follow At least COLD SHUTDOWN following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

OWN within the subs Where corrective measures are completed that perm measured from the time of failure permit operation under the ACTION requirements, the action may be taken in accordance accordan with the specified time limits as accord ilure to meet the Limiting Lim Condition for Operation. Exceptions 3.0.4 D

to these requirements are R

When an LCO e stated in the individual individ This specification is not applicable in MO O is not met, entry Applicability shall only be e made:

specifications.

MODE 5 or 6.

en into a MODE or other specified condition in the

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 SEABROOK - UNIT 1 3/4 0-1 Amendment No. 57, 114

SBK INSERT APPLICABILITY 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.

3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated ACTIONS 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 time interval, completion of the required ACTION(S) is not required unless otherwise stated.

T AF DR

APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.4 (Continued)

INSERT LCO 3.0.6 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.

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 Specifications 3.0.1 and 3.0.2 for the system returned eturn to service under eturne administrative control to perform the testing required to demonstrate emo emonstrat OPERABILITY.

SURVEILLANCE REQUIREMENTS AF 4.0.1 Surveillance Requirements shall be met during ng Conditions other conditions specified for individual Limiting uring the OP OPERATIO OPERATIONAL MODES or nditions for Operation ce Requirement. Failure otherwise stated in an individual Surveillance Ope unless Failu to meet a Surveillance, the Limiting Condition for Operation T whether such failure is experienced during performances of the Surveillance, shall not have to be performed on inoperable ng the performance of all be failure ailure to meet the Failure to perform a Surveillance within the specified o the Surveillance or between t Limiting Condition for Operation.

th specifie surveillance tion except as provided surv provide pro interval shall be failure to meet in Specification 4.0.3. Surveillances do noperable equipment or variables outside specified limits.

D 4.0.2 Each Surveillance surveillance interval with R

the specified surveillance e Requirement shall be performed within the specified th a maximum allowable ance interval.

allowab extension not to exceed 25 percent of allow 4.0.3 If it is discovered that a Surveillance not met may be delayed, from Survei Surve interval, then compliance with the requirement r

was not performed within its specified surveillance to declare the Limiting Condition for Operation the time of discovery, 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 m th specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

SEABROOK - UNIT 1 3/4 0-2 Amendment No. 69, 87, 114

INSERT LCO 3.0.6 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the 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 6.7.6.o, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

T AF DR

CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3 Each containment isolation valve shall be OPERABLE*.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one or more of the isolation valve(s) inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and:

a. Restore the inoperable valve(s) to OPERABLE BLE status s within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or

b. Isolate each affected penetration within n 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use u of at least one c.

deactivated automatic valve secured Isolate each affected penetration T

d in the isolation position, on within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> h

posit po or use of at least one closed by u D

manual valve or blind flange;; or o

d.Be in at least HOT STANDBY ANDBY Y within the nexnext 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 4.6.3.1 R

SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS AF Not used MEN MENTS hour

---

NOTES-----------------------------------------

1. Enter applicable ACTIONS for system made inoperable by containment isolation valves

2. Enter the ACTION of LCO 3.6.1.2, "Containment Leakage," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

4.6.3.2 Each containment isolation valve shall be demonstrated OPERABLE during ment isolatio isolat shutdown in accordance with the Surveillance Frequency Control Program by:

a. Verifying that on a Phase "A" Isolation test signal, each Phase "A" Isolation valve actuates to its isolation position,

b. Verifying that on a Phase "B" Isolation test signal, each Phase "B" Isolation valve actuates to its isolation position, and

• Locked or sealed closed valves may be opened on an intermittent basis under administrative control.

SEABROOK - UNIT 1 3/4 6-16 Amendment No. 120, 141

Seabrook Table of Support System Actions that Direct Entering Actions of Supported Systems T

AF DR

ATTACHMENT 3 T able of Support System Actions that Direct Entering Actions of Supported Systems (Seabrook)

ISTS LCO ISTS Action or Note Seabrook TS LCO Seabrook Proposed TS Action or Note 3.3.5, LOP DG C.1 Enter applicable Condition(s) and N/A Seabrook TS do not include an LCO for Start Required Action(s) for the associated LOP DG Start Instrumentation.

Instrumentation DG made inoperable by LOP DG start instrumentation.

3.3.6,Containment B.1 Enter applicable Conditions and Required N/A Seabrook TS do not include an LCO for Purge and Exhaust Actions of LCO 3.6.3, "Containment Containment Purge and Exhaust Isolation Isolation Isolation Valves," for containment purge and Instrumentation.

Instrumentation exhaust isolation valves made inoperable by isolation instrumentation.

C.2 Enter applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for containment purge and exhaust isolation valves made inoperablee byy isolation instrumentation T

3.3.7, CREFS B.1.2 Enter applicable Conditions and N/A Seabrook TS do not include an LCO for Actuation Instrumentation Required Actions for one CREFS inoperable by inoperable CREFSREFS FS train m made EFS actuation ation F CREFS Actuation Instrumentation.

instrumentation.

3.3.8, FBACS Actuation B.1.2 Enter applicablee Conditions and Required Actions of LCO 3.7.13, "Fuel A N/A Seabrook TS do not include an LCO for FBACS Actuation Instrumentation Instrumentation Building Air Cleanup nup System S (FBACS),"

BACS)," for erable by inopera one train made inoperable inope inoperable 3.4.14, RCS PIV actuation instrumentation.

on.

2. Enter applicable Conditions R

ions and Required 3.4.6.2, Reactor Proposed note to Action c:

Leakage Actions for systems made inoperable by an D Coolant System inoperable PIV. Leakage Enter applicable ACTIONS for systems made inoperable by an inoperable pressure isolation valve.

Page 1 of 4

ATTACHMENT 3 T able of Support System Actions that Direct Entering Actions of Supported Systems (Seabrook)

ISTS LCO ISTS Action or Note Seabrook TS LCO Seabrook Proposed TS Action or Note 3.6.2, Containment 3. Enter applicable Conditions and Required 3.6.1.3, Containment Proposed note to Actions:

Air Locks Actions of LCO 3.6.1, "Containment," when Air Locks Enter the ACTION of LCO 3.6.1.2, air lock leakage results in exceeding the "Containment Leakage," when air lock overall containment leakage rate. leakage results in exceeding the overall containment leakage rate.

3.6.3, Containment 3. Enter applicable Conditions and Required 3.6.3, Containment ment Proposed notes to Actions:

Isolation Valves Actions for systems made inoperable by Isolation Valves alves 1. Enter applicable ACTIONs for systems containment isolation valves. made ma inoperable by containment isolation

4. Enter applicable Conditions and Required valves.

val Actions of LCO 3.6.1, "Containment," when 2. Enter the ACTION of LCO 3.6.1.2, isolation valve leakage results in exceeding the "Containment Leakage," when isolation overall containment leakage rate valve leakage results in exceeding the acceptance criteria.

F T overall containment leakage rate acceptance criteria.

3.7.7, Component A.1 --------------NOTE--------------- 3.7.3, 3 Pr Primary Proposed note to Action:

Cooling Water Enter applicable Conditions and Required Component Co Com Cooling Enter applicable ACTIONS of LCO Actions of LCO 3.4.6, "RCS CS Loops Loop - Water W 3.4.1.3, "Reactor Coolant Loops and MODE 4," for residual heatt removal loops l

made inoperable by CCW.

A Coolant Circulation," for residual heat removal loop made inoperable by PCCW.

3.7.8, Service Water A.1 --------------NOTES-------------

OTES-------------

OTES -- 3.7.4, Service Proposed notes to Action:

1. Enter applicable Conditions Required Actions of LCO onditions and O 3.8.1, "AC me Sources - Operating," for emergency R

diesel Water/Ultimate Heat Sink

1. Enter applicable ACTIONs of LCO 3.8.1.1, AC Sources - Operating, for diesel generator made inoperable by generator made inoperable by SWS. service water.

D

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops- MODE

2. Enter applicable ACTION of LCO 3.4.1.3, Reactor Coolant Loops and 4," for residual heat removal loops made Coolant Circulation, for residual heat inoperable by SWS. removal loop made inoperable by service Page 2 of 4

ATTACHMENT 3 T able of Support System Actions that Direct Entering Actions of Supported Systems (Seabrook)

ISTS LCO ISTS Action or Note Seabrook TS LCO Seabrook Proposed TS Action or Note water.

3.8.1, AC Sources - A.2 Declare required feature(s) with no Proposed change to Action a to add:

Operating offsite power available inoperable when Declare required feature(s) with no offsite its redundant required feature(s) is inoperable.

power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite o power to one train concurrent with inoperability ino of redundant required feature(s);

fe B.2 Declare required feature(s) supported by No change required. Action d provides the inoperable DG inoperable when its the necessary restriction for cross train required redundant feature(s) is inoperable.

C.1 Declare required feature(s) inoperable when its redundant required feature(s) able (s) is e.

3.8.1.1, AC Sources Operating Sou S

T inoperabilities.

Proposed change to Action e to add:

Declare required feature(s) inoperable inoperable.

F when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery A two offsite circuits inoperable concurrent with inoperability of redundant required feature(s);

D. --------------------NOTE-------------------

-NOTE NO --------------

---

Proposed Note to Action c:

Enter applicable Conditions nditions and Required Req Re Actions of LCO 3.8.9, "Distribution R

"Distributi Systems

- Operating," when Condition tion D is entered Enter applicable ACTIONs of LCO 3.8.3.1, Onsite Power Distribution -

Operating," when ACTION c is entered with no AC power source to any train. with no AC power to any train.

3.8.2, AC Sources -

Shutdown Enter applicable Conditions and D

A. --------------------NOTE------------------- 3.8.1.2, A.C. Sources -

Shutdown Proposed note to Action:

Enter the ACTION of LCO 3.8.3.2, Required Actions of LCO 3.8.10, Onsite Power Distribution - Shutdown, with one required train de-energized when one required train de-energized as a Page 3 of 4

ATTACHMENT 3 T able of Support System Actions that Direct Entering Actions of Supported Systems (Seabrook)

ISTS LCO ISTS Action or Note Seabrook TS LCO Seabrook Proposed TS Action or Note as a result of Condition A. result of inoperable offsite circuit.

3.8.7, Inverters - A.1 --------------NOTE-------------- N/A Seabrook TS do not include an LCO for Operating Enter applicable Conditions and Required Inverters- Operating Actions of LCO 3.8.9, "Distribution Systems

- Operating" with any AC vital bus deenergized.

3.8.9, Distribution A.1 --------------NOTE------------------ 3.8.3.1, Onsite Power Powe Proposed Pr note to Action a:

Systems - Enter applicable Conditions and Required Distribution bution -

buti Enter En applicable ACTION of LCO 3.8.2.1, Operating Actions of LCO 3.8.4, "DC Sources - Operating perati perating "DC Sources - Operating," for DC trains Operating," for DC trains made inoperable by made inoperable by inoperable AC power inoperable power distribution subsystems. distribution system.

F T A

R D

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