ML061080409

Application for Technical Specification Change to Add/Revise LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

ML061080409
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	04/11/2006
From:	Gordon Peterson Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML061080409 (33)

Text

Duke GARY R. PETERSON n er Vice President 1%ne~rgyo -McGuire Nuclear Statbn Duke Energy Corporation April 11, 2006 MGOIVP / 12700 Hajers Ferry Rd.Huntersville, NC 28078 U. S. Nuclear Regulatory Commission 704 875 5333 Washington, D.C. 20555-0001 704 875 4809 fax ATTENTION:

Document Control Desk grpeters@duke-energ).com

SUBJECT:

Oconee Nuclear Station, Units 1, 2, and 3-Docket Nos. 50-269, 50-270, and 50-287 McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Application for Technical Specification Change to Add/Revise LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process (CLIIP)In accordance with the provisions of 10 CFR 50.90, Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) is submitting a license amendment request (LAR) for the Technical Specifications (TS) for Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2.The proposed amendment would modify TS requirements for inoperable snubbers by adding or revising LCO 3.0.8. Oconee, McGuire, and Catawba already have an NRC-approved Bases Control Program that is consistent with the TS Bases Control Program described in Section 5.5 of the applicable vendor's Standard Technical Specifications.

Thus, this portion of the CLIIP is unnecessary and is not included in this LAR submittal.

Attachment 1 provides a description of the proposed change, the!requested confirmation of applicability, and plant-specific verifications.

Attachments 2a, 2b, and 2c provide the existing TS pages marked up to show the proposed changes for Oconee, McGuire, and Catawba, respectively.

Attachment 3, containing revised (clean) TS and Bases pages, will be provided to the NRC at the time of issuance of the approved amendments.

Attachment 4 provides a summary of the regulatory commitments made in this submil:tal.

Attachments 5a, 5b, and 5c provide the existing TS Bases pages marked up to show the proposed changes for Oconee, McGuire, and Catawba, respectively.

www.duke-energy.com U. S. Nuclear Regulatory Commission April 11, 2006 Page 2 Implementation of this addition/revision to the TS will not affect the Oconee, McGuire, or Catawba Updated Final Safety Analysis Report. In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, thae changes contained in this LAR have been reviewed and approved :Dy the respective Oconee, McGuire, or Catawba Plant Operations Review Committee.

This LAR has also been reviewed and approved by the Duke Nuclear Safety Review Board. Duke requests NRC approval of this CLIIP item by October 15, 2006, with each station's implementation to take place within 120 days after t:he completion of the Fall 2006 refueling outages on Oconee Unit 1, McGuire Unit 2, and Catawba Unit 1.In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated official of the State of North Carolina and to the designated official of the State of South Carolina.If you should have any questions regarding this submittal, please contact J. S. Warren at 704-875-5171.

Since < y, Gary R. Peterson Attachments:

1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-ups) for Oconee (Attachment 2a), McGuire (Attachment 2b), and Catawba (Attachment 2c)3. Revised Technical Specifications and Bases Pages (FUTURE)4. Regulatory Commitments

5. Proposed Technical Specifications Bases Changes (Mark-ups) for Oconee (Attachment 5a), McGuire (Attachment 5b), and Catawba (Attachment 5c)

U. S. Nuclear Regulatory Commission April 11, 2006 Page 3 xc w/Attachments:

W. D. Travers U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan (Addressee Only)NRC Project Manager (Oconee)U. S. Nuclear Regulatory Commission Mail Stop 8 G9A Washington, DC 20555-0001 J. F. Stang (Addressee Only)NRC Project Manager (McGuire & Catawba)U. S. Nuclear Regulatory Commission Mail Stop 8 H4A Washington, DC 20555-0001 M. C. Shannon Senior Resident Inspector (Oconee)U. S. Nuclear Regulatory Commission Oconee Nuclear Site J. B. Brady Senior Resident Inspector (McGuire)U. S. Nuclear Regulatory Commission McGuire Nuclear Site E. F. Guthrie Senior Resident Inspector (Catawba)U. S. Nuclear Regulatory Commission Catawba Nuclear Site U. S. Nuclear Regulatory Commission April. 11, 2006 Page 4 xc w/Attachments (cont.): Beverly 0. Hall, Section Chief Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645 H. J. Porter, Director Division of Radioactive Waste Management South Carolina Bureau of Land and Waste Management 2600 Bull Street Columbia, SC 29201 U. S. Nuclear Regulatory Commission April. 11, 2006 Page 5 Gary R. Peterson, affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Gary R. eterson, Site Vice President Subscribed and sworn to me: A/1ri , wash Date____, Notary Public My commission expires: e isi Date_, =DEALA.

Attachment 1 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding or revising LCO 3.0.8. Oconee, McGuire, and Catawba already have an NRC-approved Bases Control Program that is consistent with the TS Bases Control Program described in Section 5.5 of the applicable vendor's Standard Technical Specifications (STS).The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-372, Revision 4. The availability of this TS improvement was published in the Federal Register on May 4, 2005, as part of the Consolidated Line Item Improvement Process (CLIIP).2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke)has reviewed the safety evaluation dated May 4, 2005, 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.

Duke has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Oconee Nuclear Station, Units 1, 2, and 3; McGuire Nuclear Station, Units 1 and 2; and Catawba Nuclear Station, Units 1 and 2, and justify this amendment for the incorporation of the changes to the Oconee, McGuire, and Catawba TS.2.2 Optional Changes and Variations Duke is not proposing any variations or deviations from the TS changes described in TSTF-372, Revision 4, or the NRC staff's model safety evaluation dated May 4, 2005.1 Attachment 1 Description and Assessment 3.0 REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination Duke has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. Duke has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Oconee, McGuire, and Catawba and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on May 4, 2005, for this TS improvement, plan:-specific verifications were performed as follows: Duke has established 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 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 t:o perform their associated support function.

Finally, Duke has a Bases Control Program consistent with Section 5.5 of the STS.4.0 E:NVIRONMENTAL EVALUATION Duke has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005, as part of the CLIIIP.Duke has concluded that the staff's findings presented in that evaluation are applicable to Oconee, McGuire, and Catawba and the evaluation is hereby incorporated by reference for this application.

2 Attachment 2a Proposed Technical Specifications Changes (Mark-up)Oconee Nuclear Station Units 1, 2, and 3 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other s ecified conditions in the Applicability, except as provided in LCO 3.0._, j Gage tao 0¢.f t LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in: a. MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />;b. MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />; and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except 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.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.OCONEE UNITS 1, 2, & 3 3.0-1 Amendment Nos.(,(D LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Exceptions to this Specification are'stated in the individual Specifications.(continued)

LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.16, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.LCO 3.0.7 Test Exception LCO 3.1.8 allows specified Technical Specification (TVS)requirements to be changed to permit performance of special tests and operations.

Unless otherwise specified, all other TS requirements remain unchanged.

Compliance with Test Exception LCOs is optional.

When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

t _ _IN5E T i)l OCONEE UNITS 1, 2, & 3 3.0-2 Amendment Nos.3,0 30 HOO INSERT I 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.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.

Attachment 2b Proposed Technical Specifications Changes (Mark-up)McGuire Nuclear Station Units 1 and 2 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 3.0.2P. 3.7 .I ,4 _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 arid LCO 3.0.6.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in: a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.3.0-1 Amendment Nos.1/2I McGuire Llnits 1 and '

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.7 Test Exception LCOs 3.1.8 and 3.4.17 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations.

Unless otherwise specified, all other TS requirements remain unchanged.

Compliance with Test Exception LCOs is optional.

When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO0lb LCOs including the associated ACTIONS shall apply to each unit individually unless otherwise indicated as follows: a. Whenever the LCO refers to systems or components which are shared by both units, the ACTIONS will apply to both units simultaneously;

b. Whenever the LCO applies to only one unit, this will be identified in the Applicability section of the Specification; and c. Whenever certain portions of a Specification contain operating parameters, setpoints etc., which are different for each unit, this will be identified in parentheses or footnotes. (For example, ... flow rate of 54,000 cfm (Unit 1) or 43,000 cfm (Unit 2)...").McGuire Llnits 1 and 2 3.0-3 Amendment NosJ/t3 INSERT 1 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.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.

Attachment 2c Proposed Technical Specifications Changes (Mark-up)Catawba Nuclear Station Units 1 and 2 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 2.0.1 LCOs shall be met during the MODES or other s ecified conditions in the Applicability, except as provided in LCO 3.0.2 A 3.0.7 I LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in: a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.(continued)

Amendment Nos.(@D Catawba Units 1 and 2 3.0-1 LCO Applicability

3.0 3.0 LCO APPLICABILITY (continued)

LCO '1.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDPi'." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.LCO 3.0.7 LOG 3 LCO 3.0gr-Test Exception LCOs 3.1.8 and 3.4.17 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations.

Unless otherwise specified, all other TS requirements remain unchanged.

Compliance with Test Exception LCOs is optional.

When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCOs including the associated ACTIONS shall apply to each unit individually unless otherwise indicated as follows: a. Whenever the LCO refers to systems or components which are shared by both units, the ACTIONS will apply to both units simultaneously;

b. Whenever the LCO applies to only one unit, this will be identified in the Applicability section of the Specification; and c. Whenever certain portions of a Specification contain operating parameters, setpoints etc., which are different for each unit, this v/ill be identified in parentheses or footnotes. (For example, "...flow rate of 54,000 cfm (Unit 1) or 43,000 cfm (Unit 2)...").Catawba Units 1 and 2 3.0-3 Amendment Nos. 92D/

INSERT 1 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.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.

Attachment 3 (FUTURE)Proposed Technical Specifications and Bases Pages Attachment 4 List of Regulatory Commitments The following table identifies those actions committed to by Duke Energy Corporation (Duke) in this document.

Any other statements in this submittal are provided for informational purposes and are not considered to be regulatory commitments.

Please direct questions regarding these commitments to J. S. Warren at 704-875-5171.

REGULATORY COMMITMENTS DUE DATE/EVENT Duke has established the Technical Implemented with Specifications Bases for LCO 3.0.8 as amendment.

adopted with the applicable license amen nent. I Attachment 5a Proposed Technical Specifications Bases Changes (Mark-up)Oconee Nuclear Station Units 1, 2, and 3 LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, thD 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 ACTIONS.)

The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time.In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

OCONEE UNITS 1, 2, & 3 B 3.0-1 BASES REVISION DATED s)

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, 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 special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged.

This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.Compliance with Test Exception LCOs is optional.

A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements.

If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.OCONE-E UNITS 1, 2, & 3 B 3.0-9 BASES REVISION DATED1 03) I INSERT 2 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 required 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 required snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The 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 required 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.LCO 3.0.8.a applies when one or more required snubbers are not capable of 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the required 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 probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the required 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 required 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the required 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 concurrent with an event that would require operation of the supported system occurring while the required 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 ore or more required snubbers are not able to perform their associated support function.

Attachments 5b Proposed Technical Specifications Bases Changes (Mark-up)McGuire Nuclear Station Units 1 and 2 LCO B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.:2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that: a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

McGuire Units 1 and 2 B 3.0-1 Revision No/2 LCO Applicability B 3.0 BASES LCO (continued) safety function exists, the appropriate Conditions and Required Actions 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 required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Test Exception LCOs 3.1.8 and 3.4.17 allow specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS.Unless otherwise specified, all the other TS requirements remain unchanged.

This will ensure all appropriate requirements of the MODE Cr other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.Compliance with Test Exception LCOs is optional.

A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements.

If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.LCO 3.0t C .0 delineates the applicability of each specification to Unit 1 and Unit 2 operations.

McGuire Units 1 and 2 B 3.0-9 Revision No.X7 INSERT 2 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 duo to one or more required 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 required snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The 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 required 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.LCO 3.0.8.a applies when one or more required snubbers are not capable of 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 subsysterr supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the required 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 probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the required snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train oG the supported system.LCO 3.0.8.b applies when one or more required 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the required 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 concurrent with an event that would require operation of the supported system occurring while the required 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 ore or more required snubbers are not able to perform their associated support function.

Attachments 5c Proposed Technical Specifications Bases Changes (Mark-up)Catawba Nuclear Station Units 1 and 2

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES =LCOs LCO 3.0.1 through LCO 3.0 sablish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.LCO 3.CI.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 ACTIONS.)

The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Catawba Units 1 and 2 B 3.0-1 Revision No-9Il i LCO Applicability B 3.0 BASE,'LCO 3.0.6 (continued) 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 the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained.

If this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actiors of the LCO in which the loss of safety function exists are required to be entered.LCO 3.0.7 , ISE Tr v There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Test Exception LCOs 3.1.8 and 3.4.17 allow specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged.

This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.Compliance with Test Exception LCOs is optional.

A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements.

If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.L6- T .0LCO 3.0delineates the applicability of each specification to Unit 1 arid Unit 2 operations.

Catawba Units 1 and 2 B 3.0-9 Revision No.t i INSERT 2 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 duo to one or more required 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 required snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The 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 required 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.LCO 3.0.8.a applies when one or more required snubbers are not capable of 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 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the required 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 probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the required snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train ol the supported system.LCO 3.0.8.b applies when one or more required 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the required 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 concurrent with an event that would require operation of the supported system occurring while the required 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 required snubbers are not able to perform their associated support function.