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TSTF-505 Near Term Revised Draft - Change Tracking Copy for 09/12/2017 Teleconference
	ML17258A126
Person / Time
Site:	Technical Specifications Task Force
Issue date:	09/12/2017
From:	; Technical Specifications Task Force
To:	; Office of Nuclear Reactor Regulation
	Honcharik M, 301-415-1774, DSS/STSB
Shared Package
ML17258A124	List: ML17258A126; ML17258A127;
References
	Download: ML17258A126 (96)
	v • d • e

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF DATE DRAFT TSTF-17-01 REVISION 13 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to NRC Questions on TSTF-505-A, "Provide Risk-Informed Extended Completion Times"

Reference:

Letter from T. McGinty and A. Boland (NRC) to Technical Specifications Task Force (TSTF), "Issues with Technical Specifications Task Force Traveler TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b'," dated November 15, 2016 In the referenced letter, the NRC raised concerns with approved TSTF traveler, TSTF-505-A, Revision 1, "Provide Risk-Informed Extended Completion Times." The NRC published in the Federal Register a notice of availability for the Model Safety Evaluation (SE) for plant-specific adoption of TSTF traveler TSTF-505, Revision 1, on March 15, 2012. Currently, six several licensees have License Amendment Requests (LARs) under NRC review to adopt risk-informed Completion Times.

On December 13, 2016, the TSTF and the Nuclear Energy Institute (NEI) met with the NRC to discuss the NRC's concerns. Most of the NRC concerns were related to proposed Technical Specifications (TS) Actions related to all trains of a TS required system being inoperable (i.e.,

loss of function). The industry proposed the following short-term and long-term actions to resolve the NRC concerns:

1. The industry will pursue development of a companion traveler for TSTF-505-A that addresses the NRC issues with Actions related to inoperability of all trains of a TS required systema loss of function. Following approval, plants that have adopted TSTF-505-A without these Actions related to a loss of function could submit a LAR to adopt the companion traveler. Following NRC approval of the companion traveler, plants that have not adopted TSTF-505-A can adopt TSTF-505-A and the companion traveler in a single LAR.

2. TSTF-505-A allows licensees to choose which Action changes are included in their LAR.

The TSTF will recommend to the industry that until the companion traveler is approved by the NRC, licensees submitting LARs to adopt TSTF-505 follow the guidance in the attachments to this letter. Actions related to the inoperability of all trains of a TS required system should not be included in LARs submitted prior to approval of the companion

TSTF-17-01 DATE traveler. not include Action changes related to a loss of function. Omitting these Actions and incorporating the other changes recommended in the attachments to this letter should allow timely approval of LARs and provide the majority of the benefit of TSTF-505. contains a list of the Actions revised by TSTF-505-A that should be omitted in LARs submitted prior to approval of the companion traveler. Attachment 1 also includes, as well as conforming changes to the TSTF-505-A Section 1.3 TS example and the TS Section 5.5 Administrative Controls program. Attachment 2 contains a list of Actions revised by TSTF-505-A that have conditions on their inclusion in a plant-specific LAR. Attachment 3 contains a revised Mode Application for requesting adoption of TSTF-505-A.

3. The proposed actions only apply to future submittals. The licensees with LARs currently under NRC review will decide how to proceed.

The TSTF has been informed by Southern Nuclear Operating Company that the Vogtle LAR will proceed with limited Risk Informed Completion Times for loss-of-function conditions. The TSTF encourages the NRC to expeditiously complete the Vogtle LAR review, as it will provide valuable insight regarding loss-of-function Actions.

The NRC had questions on other aspects of TSTF-505 not related to loss of function. Those questions are addressed in Attachment 2.

The TSTF requests that the NRC rescind the suspension of the approval of TSTF-505-A, Revision 1, and accept LARs to adopt TSTF-505-A that follow the recommendations in the attachments to this letter. do not include proposed Actions with risk-informed Completion Times related to loss of function, as described in Attachment 1. Following NRC approval of a TSTF traveler that addresses Actions with a risk-informed Completion Time related to loss of function, LARs should be accepted for review that propose to adopt TSTF-505 and the companion traveler.

Should you have any questions, please do not hesitate to contact us.

James R. Morris (PWROG/W)

Lisa L. Williams (BWROG)

Otto W. Gustafson (PWROG/CE)

Jordan Vaughan (PWROG/B&W)

Jason P. Redd (APOG)

Enclosure

TSTF-17-01 DATE cc:

Mirella Gavrilas, Director of the Division of Safety Systems Anne T. Boland, Director of the Division of Operating Reactor Licensing Jennifer Whitman, Acting Chief of the Technical Specifications Branch Michelle Honcharik, Technical Specifications Branch Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to TSTF-505 Markup to NUREG-1430, Babcock and Wilcox STS Page 1 Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.1.C RPS Instrumentation LOF. Do not include Action 3.3.2.A Reactor Protection System (RPS) Manual Reactor Trip Do not include.

Action 3.3.5.B ESFAS Instrumentation LOF. Do not include Action 3.3.6.B ESFAS Manual Initiation LOF. Do not include Action 3.3.11.D EFIC System Instrumentation LOF. Do not include Action 3.3.13.B EFIC Logic LOF. Do not include Action 3.3.14.B EFIC-EFW-Vector Valve Logic LOF. Do not include Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A CFTs Do not include Action 3.5.1.B CFTs Do not include Action 3.5.1.C CFTs LOF. Do not include Action 3.5.2.C ECCS - Operating LOF. Do not include Action 3.5.3.B ECCS - Shutdown Do not include.

Action 3.5.4.A BWST Do not include Action 3.5.4.B BWST Do not include Action 3.6.3.B Containment Isolation Valves Do not include Action 3.6.3.D Containment Isolation Valves Do not include Action 3.6.6.F Containment Spray and Cooling Systems LOF. Do not include Action 3.7.2.C MSIVs LOF. Do not include Action 3.7.4.B AVVs Do not include.

Action 3.7.5.C EFW System LOF. Do not include Action 3.7.6.A CST Do not include.

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to TSTF-505 Markup to NUREG-1430, Babcock and Wilcox STS Page 2 Specification Specification Title Notes Action 3.7.8.B SWS LOF. Do not include Action 3.7.9.C UHS LOF. Do not include Action 3.7.11.B CREVS LOF. Do not include Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached recommended changes Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Page 3 Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.1.C RTS Instrumentation LOF. Do not include Action 3.3.1.E RTS Instrumentation LOF. Do not include Action 3.3.1.G RTS Instrumentation LOF. Do not include Action 3.3.1.I RTS Instrumentation LOF. Do not include Action 3.3.1.Q RTS Instrumentation LOF. Do not include Action 3.3.1.S RTS Instrumentation Do not include Action 3.3.1.T RTS Instrumentation LOF. Do not include Action 3.3.1.V RTS Instrumentation Do not include Action 3.3.1.W RTS Instrumentation LOF. Do not include Action 3.3.1.Z RTS Instrumentation LOF. Do not include Action 3.3.1.CC RTS Instrumentation LOF. Do not include Action 3.3.1.EE RTS Instrumentation LOF. Do not include Action 3.3.1.JJ RTS Instrumentation LOF. Do not include Action 3.3.2.C ESFAS Instrumentation LOF. Do not include Action 3.3.2.E ESFAS Instrumentation LOF. Do not include Action 3.3.2.G ESFAS Instrumentation LOF. Do not include Action 3.3.2.I ESFAS Instrumentation LOF. Do not include Action 3.3.2.K ESFAS Instrumentation LOF. Do not include Action 3.3.2.M ESFAS Instrumentation LOF. Do not include Action 3.3.2.O ESFAS Instrumentation LOF. Do not include Action 3.3.2.Q ESFAS Instrumentation LOF. Do not include Action 3.3.2.S ESFAS Instrumentation LOF. Do not include Action 3.3.2.U ESFAS Instrumentation LOF. Do not include Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Page 4 Specification Specification Title Notes Action 3.3.2.V ESFAS Instrumentation Do not include. Required Action outside the scope of TSTF-505.

Action 3.3.9.B BDPS LOF. Do not include Action 3.4.9.C Pressurizer LOF. Do not include.

Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.11.E Pressurizer Power Operated Relief Valves (PORVs)

Do not include.

Action 3.4.11.F Pressurizer Power Operated Relief Valves (PORVs)

Do not include.

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A Accumulators Do not include.

Action 3.5.1.B Accumulators Do not include.

Action 3.5.1.C Accumulators LOF. Do not include.

Action 3.5.2.B ECCS - Operating LOF. Do not include.

Action 3.5.3.B ECCS - Shutdown Do not include.

Action 3.5.4.A RWST Do not include.

Action 3.5.4.B RWST Do not include.

Action 3.5.6.A Boron Injection Tank Do not include.

Action 3.6.3.B Containment Isolation Valves Do not include.

Action 3.6.3.C Containment Isolation Valves Do not include.

Action 3.6.3.D Containment Isolation Valves Do not include.

Action 3.6.3.E Containment Isolation Valves Do not include.

Action 3.6.6A.E Containment Spray and Cooling Systems (Atmospheric and Dual)

LOF. Do not include.

Action 3.6.6B.G Containment Spray and Cooling Systems (Atmospheric and Dual)

LOF. Do not include.

Action 3.6.6C.B Containment Spray System (Ice Condenser)

LOF. Do not include.

Action 3.6.6D.B QS System (Subatmospheric)

LOF. Do not include.

Action 3.6.6E.F RS System (Subatmospheric)

LOF. Do not include.

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Page 5 Specification Specification Title Notes Action 3.6.9.B Hydrogen Mixing System Do not include.

Action 3.6.10.C HIS (Ice Condenser)

LOF. Do not include.

Action 3.6.14.B ARS (Ice Condenser)

LOF. Do not include.

Action 3.6.15.A Ice Bed Do not include.

Action 3.6.17.A Divider Barrier Integrity (Ice Condenser)

Do not include.

Action 3.6.17.B Divider Barrier Integrity (Ice Condenser)

Do not include.

Action 3.6.18.A Containment Recirculation Drains (Ice Condenser)

LOF. Do not include.

Action 3.6.18.B Containment Recirculation Drains (Ice Condenser)

LOF. Do not include.

Action 3.7.2.C MSIVs LOF. Do not include.

Action 3.7.5.C AFW System LOF. Do not include.

Action 3.7.6.A Condensate Storage Tank Do not include.

Action 3.7.7.B CCW System LOF. Do not include.

Action 3.7.8.B SWS LOF. Do not include.

Action 3.7.9.C UHS LOF. Do not include.

Action 3.7.11.B CREATCS LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached Recommended Changes Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1432, Combustion Engineering STS Page 6 Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.4.B ESFAS Instrumentation (Analog)

LOF. Do not include.

Action 3.3.5.B ESFAS Logic and Manual Trip (Analog)

LOF. Do not include.

Action 3.3.5.E ESFAS Logic and Manual Trip (Analog)

LOF. Do not include.

Action 3.3.6.A ESFAS Logic and Manual Trip (Digital)

Do not include.

Action 3.3.6.E ESFAS Logic and Manual Trip (Digital)

LOF. Do not include.

Action 3.4.9.C Pressurizer LOF. Do not include.

Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.11.E Pressurizer Power Operated Relief Valves (PORVs)

Do not include.

Action 3.4.11.F Pressurizer Power Operated Relief Valves (PORVs)

Do not include.

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A SITs Do not include.

Action 3.5.1.B SITs Do not include.

Action 3.5.1.C SITs LOF. Do not include.

Action 3.5.2.C ECCS - Operating LOF. Do not include.

Action 3.5.3.A ECCS - Shutdown Do not include.

Action 3.5.4.A RWT Do not include.

Action 3.5.4.B RWT Do not include.

Action 3.6.3.C Containment Isolation Valves Do not include.

Action 3.6.3.E Containment Isolation Valves Do not include.

Action 3.6.3.F Containment Isolation Valves Do not include.

Action 3.6.6A.F Containment Spray and Cooling Systems (Atmospheric and Dual)

LOF. Do not include.

Action 3.6.6B.F Containment Spray and Cooling Systems (Atmospheric and Dual)

LOF. Do not include.

Action 3.6.9.B Hydrogen Mixing System Do not include.

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1432, Combustion Engineering STS Page 7 Specification Specification Title Notes Action 3.7.2.C MSIVs LOF. Do not include.

Action 3.7.4.B Atmospheric Dump Valves Do not include.

Action 3.7.5.C AFW System LOF. Do not include.

Action 3.7.6.A Condensate Storage Tank Do not include.

Action 3.7.7.B CCW System LOF. Do not include.

Action 3.7.8.B SWS LOF. Do not include.

Action 3.7.9.C UHS LOF. Do not include.

Action 3.7.10.B ECW LOF. Do not include.

Action 3.7.12.B CREATCS LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include.

Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached recommended changes Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1433, BWR/4 STS Page 8 Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.1.7.A SLC System Do not include.

Action 3.1.7.C SLC System Do not include.

Action 3.3.1.1.C Reactor Protection System (RPS) Instrumentation Do not include.

Action 3.3.4.1.B End of Cycle Recirculation Pump Trip (EOC-RPT)

Instrumentation Do not include.

Action 3.3.4.2.B Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Instrumentation Do not include.

Action 3.3.4.2.C Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Do not include.

Action 3.3.5.2.C Reactor Core Isolation Cooling (RCIC) System Instrumentation Do not include.

Action 3.3.6.1.B Primary Containment Isolation Instrumentation Do not include.

Action 3.3.6.3.C LLS Instrumentation Do not include.

Action 3.3.6.3.D LLS Instrumentation LOF. Do not include.

Action 3.4.3.B S/RVs LOF. Do not include.

Action 3.5.1.G ECCS - Operating LOF. Do not include.

Action 3.5.1.I ECCS - Operating LOF. Do not include.

Action 3.6.1.3.B PCIVs Do not include. Required Action outside the scope of TSTF-505.

Action 3.6.1.3.C PCIVs Do not include. Required Action outside the scope of TSTF-505.

Action 3.6.2.3.B Residual Heat Removal (RHR) Suppression Pool Cooling Do not include.

Action 3.6.2.4.B Residual Heat Removal (RHR) Suppression Pool Spray Do not include.

Action 3.6.3.3.B Containment Atmosphere Dilution (CAD) System Do not include.

Action 3.7.1.D Residual Heat Removal Service Water (RHRSW)

System Do not include.

Action 3.7.2.F

[PSW] System and [UHS]

LOF. Do not include.

Action 3.7.5.B

[Control Room AC] System LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1433, BWR/4 STS Page 9 Specification Specification Title Notes Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.15 Risk Informed Completion Time Program See attached recommended changes Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1434, BWR/6 STS Page 10 Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.1.7.A SLC System Do not include.

Action 3.1.7.C SLC System Do not include.

Action 3.3.1.1.C Reactor Protection System (RPS) Instrumentation Do not include.

Action 3.3.4.1.B End of Cycle Recirculation Pump Trip (EOC-RPT)

Instrumentation Do not include.

Action 3.3.4.2.B Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Instrumentation Do not include.

Action 3.3.4.2.C Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Instrumentation Do not include.

Action 3.3.5.2.C Reactor Core Isolation Cooling (RCIC) System Instrumentation Do not include.

Action 3.3.6.1.B Primary Containment Isolation Instrumentation Do not include.

Action 3.3.6.4.B Suppression Pool Makeup (SPMU) System Instrumentation Do not include.

Action 3.3.6.4.C Suppression Pool Makeup (SPMU) System Instrumentation Do not include.

Action 3.3.6.5.B Relief and LLS Instrumentation LOF. Do not include.

Action 3.4.4.B S/RVs LOF. Do not include.

Action 3.5.1.G ECCS - Operating LOF. Do not include.

Action 3.5.1.I ECCS - Operating LOF. Do not include.

Action 3.5.1.J ECCS - Operating LOF. Do not include.

Action 3.5.1.K ECCS - Operating LOF. Do not include.

Action 3.5.1.L ECCS - Operating LOF. Do not include.

Action 3.6.1.3.B Primary Containment Isolation Valves (PCIVs)

Do not include.

Action 3.6.1.3.C Primary Containment Isolation Valves (PCIVs)

Do not include.

Action 3.6.1.3.D Primary Containment Isolation Valves (PCIVs)

Do not include.

Action 3.6.1.7.B Residual Heat Removal (RHR) Containment Spray System Do not include.

Action 3.6.2.3.B Residual Heat Removal (RHR) Suppression Pool Cooling Do not include.

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1434, BWR/6 STS Page 11 Specification Specification Title Notes Action 3.6.2.4.A SPMU System Do not include.

Action 3.6.2.4.B SPMU System Do not include.

Action 3.6.2.4.D SPMU System LOF. Do not include.

Action 3.6.3.1.B Drywell Cooling System Fans Do not include.

Action 3.6.3.2.B Drywell Purge System Do not include.

Action 3.6.5.1.A Drywell Do not include.

Action 3.6.5.3.B Drywell Isolation Valve[s]

Do not include.

Action 3.6.5.6.D Drywell Vacuum Relief System Do not include.

Action 3.6.5.6.E Drywell Vacuum Relief System Do not include.

Action 3.6.5.6.F Drywell Vacuum Relief System LOF. Do not include.

Action 3.7.1.D

[SSW] System and [UHS]

LOF. Do not include.

Action 3.7.4.B

[Control Room AC] System LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.15 Risk Informed Completion Time Program See attached recommended changes Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function Recommended Changes to the Section 1.3 Example in TSTF-505 Page 12

Reviewer's Note ------------------------------------------

Example 1.3-8 is only applicable to plants that have adopted the Risk Informed Completion Time Program.

[

EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. --- NOTE ------

Not applicable when second subsystem intentionally made inoperable.

Two subsystems inoperable.

B.1 Restore subsystems to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program BC.Required Action and associated Completion Time not met.

BC.1 Be in MODE 3.

AND BC.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function Recommended Changes to the Section 1.3 Example in TSTF-505 Page 13 When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition BC must also be entered.

If a second subsystem is declared inoperable, Condition B may also be entered. The Condition is modified by a Note stating it is not applicable if the second subsystem is intentionally made inoperable. The Required Actions of Condition B are not intended for voluntary removal of redundant subsystems from service. The Required Action is only applicable if one subsystem is inoperable for any reason and the second subsystem is found to be inoperable, or if both subsystems are found to be inoperable at the same time. If Condition B is applicable, at least one subsystem must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or Condition C must also be entered. The licensee may be able to apply a RICT to extend the Completion Time beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months if the requirements of the Risk Informed Completion Time Program are met. If two subsystems are inoperable and Condition B is not applicable (i.e., the second subsystem was intentionally made inoperable), LCO 3.0.3 is entered as there is no applicable Condition.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A or the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time clock of Condition B have has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition BC is also entered and the Completion Time clocks for Required Actions BC.1 and BC.2 start.

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE status, Condition BC is also entered and the Completion Time clocks for Required Actions BC.1 and BC.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition BC is entered, Conditions A, B, and BC are exited, and therefore, the Required Actions of Condition BC may be terminated. ]

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program Page 14

[ 5.5.18 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days;

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

The Risk Informed Completion Time is only applicable in MODES supported by the Licensees PRA. Licensee's applying the RICT Program to MODES other than Modes 1 and 2 must demonstrate that they have the capability to calculate a RICT in those MODES or that the risk indicated by their MODE 1 and 2 PRA model is bounding with respect to the lower MODE conditions.

b.

A RICT may only be utilized in MODE 1, 2 [, and 3, and MODE 4 while relying on steam generators for heat removal];

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d.

Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e.

Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09.]

Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program Page 15

d.

If the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1. Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

[This paragraph will describe when prior NRC approval is needed for changes to the methodology used to calculate a RICT. The wording for this provision is currently under discussion between the NRC and the industry.]

Discussion of Recommended Changes to the Risk Informed Completion Time Program

1.

The reference to NEI 06-09 is revised to refer to the approved version, NEI 06-09-A, Revision

0.

2.

Paragraphs d. and e. of TSTF-505 are deleted. These paragraphs discuss determining a RICT when all trains of a system are inoperable and are not applicable to the near-term submittals that are the subject of this letter.

3.

The NRC questioned the difference between the TSTF-505 Risk Informed Completion Time (RICT) Program in paragraph 5.5.c and the NEI 06-09 Configuration Risk Management Program (CRMP). The traveler justification stated that the TS Section 5.5 RICT Program was the same as the NEI 06-09 CRMP; however, users of the TS may not have TSTF-505 available, which may lead to confusion when applying NEI 06-09 in accordance with the TS 5.5 RICT Program. The program was revised to clarify the application of the requirements.

4.

A new paragraph d. is added addressing common cause failure considerations.

5.

A new paragraph e. is added. The NRC's Safety Evaluation for NEI 06-09 stated:

As part of its review and approval of a licensees application requesting to implement the RMTS, the NRC staff intends to impose a license condition that will explicitly address the scope of the PRA and non-PRA methods approved by the NRC staff for use in the plant-specific RMTS program. If a licensee wishes to change its methods, and the change is outside the bounds of the license condition, the licensee will need NRC approval, via a license amendment, of the implementation of the new method in its RMTS program. The focus of the NRC staffs review and approval will be on the Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program Page 16 technical adequacy of the methodology and analyses relied upon for the RMTS application.

There is no legal difference between a license condition and a Technical Specification and it is less error prone to put all requirements related to calculation of a RICT in the same location.

Therefore, in lieu of a license condition, the restriction is added as paragraph e. of the program.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 17 Specification LCO Requirements and Condition Condition on Use 3.3.2.A LCO: The Reactor Protection System (RPS)

Manual Reactor Trip Function shall be OPERABLE.

Condition: Manual Reactor Trip Function inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM1].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 18 Specification LCO Requirements and Condition Condition on Use 3.3.8.B LCO: Three channels of loss of voltage Function and three channels of degraded voltage Function EDG LOPS instrumentation per EDG shall be OPERABLE.

Condition: One or more Functions with two or more channels per EDG inoperable.

Licensee must justify that two or more channels per EDG inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative would be to limit the TS Condition to when the minimum number of channels needed to perform the function are operable (assuming no additional failures).

See Note 1 at the end of.The Required Actions and Completion Times would be the same and would provide the option to calculate a RICT. Either a new condition would be created that applies when less than the minimum number of channels are operable or, depending on the construction of the TS, LCO 3.0.3 would apply. The licensee would need to justify that the function can still be performed in the revised Action.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 19 Specification LCO Requirements and Condition Condition on Use 3.3.12.B LCO: Two manual initiation switches per actuation channel for each of the following emergency feedwater initiation and control (EFIC)

Functions shall be OPERABLE:

a. Steam generator (SG) A Main Feedwater (MFW)

Isolation,

b. SG B MFW Isolation,

c. SG A Main Steam Line Isolation,

d. SG B Main Steam Line Isolation, and

e. Emergency Feedwater Actuation.

Condition: One or more EFIC Function(s) with one or both manual initiation switches inoperable in both actuation channels.

Licensee must justify that one or both channels inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of.

3.4.9.C LCO: The pressurizer shall be OPERABLE.

Condition: Capacity of pressurizer heaters

[capable of being powered by emergency power supply] less than limit.

Pressurizer is typically not modeled in the PRA. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 20 Specification LCO Requirements and Condition Condition on Use 3.4.10.A LCO: Two pressurizer safety valves shall be OPERABLE with lift settings > [2475] psig and <

[2525] psig.

Condition: One pressurizer safety valve inoperable.

The Applicable Safety Analysis section of the Bases states that the accident analysis assumes both PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM2].

3.4.14.C LCO: RCS Pressure Isolation Valve (PIV)

Leakage Condition: Decay Heat Removal (DHR) System autoclosure interlock function inoperable.

Licensee must justify that applying a RICT to the action to isolate the affected penetration is equivalent to isolating a Containment Isolation Valve and is acceptable[BM3]

3.5.1.B LCO: Two CFTs shall be OPERABLE Condition: One CFT inoperable for reasons other than to boron concentration not within limits.

The Applicable Safety Analysis Bases states that both CFTs are required to function in the event of a large break LOCA or the ECCS acceptance criteria may be violated. Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM4].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 21 Specification LCO Requirements and Condition Condition on Use 3.5.2.B LCO: Two ECCS trains shall be OPERABLE.

Condition: One or more [ECCS] trains inoperable for reasons other than one LPI subsystem inoperable.

Licensee must justify that one or more ECCS trains inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE. Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock mechanism.

Licensee must justify that an inoperable containment air lock is not a condition in which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.B LCO: One ECCS train shall be OPERABLE.

Condition: Required ECCS HPI subsystem inoperable in Mode 4.

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM5].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 22 Specification LCO Requirements and Condition Condition on Use 3.5.4.B LCO: The BWST shall be OPERABLE.

Condition: BWST inoperable for other than boron concentration or water temperature not within limits.

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM6].

3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE. Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock mechanism.

Licensee must justify that an inoperable containment air lock is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM7].

3.6.3.B LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with two [or more] containment isolation valves inoperable [for reasons other than purge valve leakage not within limit].

Licensee must justify that two or more inoperable containment isolation valves on a penetration with two valves is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM8].

3.6.3.D LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with one or more containment purge valves not within purge valve leakage limits.

Licensee must justify that inoperable containment purge valves is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM9].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 23 Specification LCO Requirements and Condition Condition on Use 3.6.6 LCO: Containment Spray and Cooling Systems Condition A: One containment spray train inoperable Condition C: One [required] containment cooling train inoperable.

Condition D: One containment spray train and one

[required] containment cooling train inoperable.

Condition E: Two [required] containment cooling trains inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.7.4.B LCO: [Two] Atmospheric Vent Valves (AW)

[lines per steam generator] shall be OPERABLE.

Condition: Two or more required AVV lines inoperable Licensee must justify that two or more inoperable ADVs is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM10].

3.7.6.A LCO: The [two] Condensate Storage Tanks (CST) shall be OPERABLE.

Condition: [Two] CSTs inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM11].

3.8.1.E Two [required] DGs inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM12].

3.8.4.A LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One [or two] battery charger[s] on one subsystem inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Page 24 Specification LCO Requirements and Condition Condition on Use 3.8.4.B LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One [or two] batter[y][ies on one subsystem] inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.7.A LCO: The required Train A and Train B inverters shall be OPERABLE.

Condition: One [required] inverter inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more AC electrical power distribution subsystems inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.B LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more AC vital buses inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more DC electrical power distribution subsystems inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 25 Specification LCO Requirements and Condition Condition on Use 3.3.1.F LCO: The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

Condition: One Power Range Neutron Flux - High channel inoperable.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR given the loss of spacial distribution of the remaining Power Range detectors. The justification can include that the Actions require periodic monitoring of spacial power distribution and imposition of compensatory limits and reduced power.

3.3.1.S LCO: The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

Condition: One Reactor Coolant Pump Breaker Position (Single Loop) channel inoperable.

This function is a single channel per RCP. Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable. Adequate justification may be that the RCP Breaker Position trip is an anticipatory trip, and the low flow trip is credited in the analysis[BM13].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 26 Specification LCO Requirements and Condition Condition on Use 3.3.1.V LCO: The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

Condition: One Reactor Coolant Breaker Position (Two Loops) channel This function is a single channel per RCP. Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable. Adequate justification may be that the RCP Breaker Position trip is an anticipatory trip, and the low flow trip is credited in the analysis[BM14].

3.3.1.DD LCO: The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

Condition: One RTB train inoperable.

There are two RTB trains and either can perform the function.

Unclear why loss of one would be considered a potential LOF.The licensee must include information regarding how the TSTF-411 conditions and limitations will be implemented (or similar conditions if TSTF-411 has not been adopted), including discussion of ATWS Mitigation System Actuation (AMSAC),

and why those actions are sufficient, including a discussion of defense in depth.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 27 Specification LCO Requirements and Condition Condition on Use 3.3.5.B LCO: [Three] channels per bus of the loss of voltage Function and [three] channels per bus of the degraded voltage Function shall be OPERABLE.

Condition: One or more Functions with two or more channels per bus inoperable.

Licensee must justify that two or more channels per bus inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of.

3.3.9.A LCO: Boron Dilution Protection System (BDPS)

Condition: One train inoperable (applicable to MODES [2,] 3, 4, and 5.)

BDPS is typically not modeled in the PRA.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 28 Specification LCO Requirements and Condition Condition on Use 3.4.9.B LCO: The pressurizer shall be OPERABLE Condition: One [required] group of pressurizer heaters inoperable.

Pressurizer is typically not modeled in the PRA. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative..

3.4.10.A LCO: [Three] pressurizer safety valves shall be OPERABLE with lift settings > [2460] psig and <

[2510] psig.

Condition: One pressurizer safety inoperable The Applicable Safety Analysis section of the Bases states that the accident analysis assumes all PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM15].

3.4.11.E LCO: Each PORV and associated block valve shall be OPERABLE.

Condition: Two [three] PORVs inoperable and not capable of being manually cycled.

Licensee must justify that all PORVs inoperable and incapable of being cycled is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM16].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 29 Specification LCO Requirements and Condition Condition on Use 3.4.11.F LCO: Each PORV and associated block valve shall be OPERABLE.

Condition: Two [three] block valves inoperable.

Licensee must justify that all block valves inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM17].

3.5.1.B LCO: [Four] ECCS accumulators shall be OPERABLE.

Condition: One accumulator inoperable for reasons other than boron concentration.

The Applicable Safety Analysis Bases state that three accumulators are required to inject to meet the ECCS acceptance criteria and the contents of one accumulator are assumed lost through the break. Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM18].

3.5.2.A LCO: Two ECCS trains shall be OPERABLE.

Condition: One or more [ECCS] trains inoperable.

Licensee must justify that one or more ECCS trains inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 30 Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE. Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock mechanism.

Licensee must justify that an inoperable containment air lock is not a condition in which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.B LCO: One ECCS train shall be OPERABLE.

Condition: Required ECCS [high head subsystem]

in operable. (Mode 4).

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM19].

3.5.4.B LCO: The Refueling Water Storage Tank (RWST) shall be OPERABLE.

Condition: RWST inoperable for reasons other than boron concentration or temperature Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM20].

3.5.6.A LCO: The Boron Injection Tank (BIT) shall be OPERABLE.

Condition: BIT inoperable Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable. If included, licensee must justify how the BIT is modeled in the PRA as it does not typically affect CDF or LERF[BM21].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 31 Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE.

Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock.

Licensee must justify that an inoperable containment air locks is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM22].

3.6.3.B LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with two [or more] containment isolation valves inoperable [for reasons other than shield building bypass leakage and containment purge valves not within leakage limit))

Licensee must justify that both inoperable containment isolation valves on a penetration is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM23].

3.6.3.C LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with one containment isolation valve inoperable (for penetrations with only one isolation valve).

Licensee must justify that inoperable containment isolation valve on a penetration is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM24].

3.6.3.D LCO: Each containment isolation valve shall be OPERABLE.

Condition: [One or more shield building bypass leakage [or purge valve leakage] not within limit].

Licensee must justify that leakage in excess of the limit is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM25].

3.6.3.E LCO: Each containment isolation valve shall be OPERABLE.

Condition: [One or more penetration flow paths with one or more containment purge valves not within leakage limits.]

Licensee must justify that excessive leakage is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM26].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 32 Specification LCO Requirements and Condition Condition on Use 3.6.6A LCO: Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System)

Condition A: One containment spray train inoperable.

Condition C: One [required] containment cooling train inoperable.

Condition D: Two [required] containment cooling trains inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.6B LCO: Containment Spray and Cooling Systems (Atmospheric and Dual (Credit not taken for iodine removal by the Containment Spray System)

Condition A: One containment spray train inoperable.

Condition B: One [required] containment cooling train inoperable.

Condition C: Two containment spray trains inoperable.

Condition D: One containment spray train and one

[required] containment cooling train inoperable.

Condition E: Two [required] containment cooling trains inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.6C.A LCO: Containment Spray System (Ice Condenser)

Condition: One containment spray train inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 33 Specification LCO Requirements and Condition Condition on Use 3.6.6D.A LCO: Quench Spray (QS) System (Subatmospheric)

Condition: One QS train inoperable Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.6E LCO: Recirculation Spray (RS) System (Subatmospheric)

Condition A: One RS subsystem inoperable.

Condition B: Two RS subsystems inoperable in one train.

Condition C: Two inside RS subsystems inoperable Condition D: Two outside RS subsystems inoperable.

Condition E: Casing cooling tank inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.16.A LCO: The ice condenser inlet doors, intermediate deck doors, and top deck [doors] shall be OPERABLE and closed.

Condition: One or more ice condenser doors physically restrained from opening Licensee must justify that one or more inoperable doors is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all doors inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 34 Specification LCO Requirements and Condition Condition on Use 3.6.17.A LCO: Divider barrier integrity shall be maintained.

Condition: One or more personnel access doors or equipment hatches open or inoperable, except for entry and exit.

Licensee must justify that one or more inoperable doors or hatches is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM27].

3.6.17.B LCO: Divider barrier integrity shall be maintained.

Condition: Divider barrier seal inoperable Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM28].

3.7.4.B LOC: [Three] Atmospheric Dump Valves (ADV) lines shall be OPERABLE.

Condition: Two or more required ADV lines inoperable Licensee must justify that two or more inoperable ADVs is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of.

3.7.6.A LOC: The Condensate Storage Tank (CST) shall be OPERABLE.

Condition: CST inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM29].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 35 Specification LCO Requirements and Condition Condition on Use 3.8.1.E LCO: The following AC electrical sources shall be OPERABLE:

Condition: Two [required] DGs inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM30].

3.8.4.A LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One [or two] battery charger[s] on one subsystem inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.4.B LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One [or two] batter[y][ies on one subsystem] inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical power subsystems shall be OPERABLE.

Condition: One DC electrical power subsystem inoperable for reasons other than Condition A [or B].

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.7.A LCO: The required Train A and Train B inverters shall be OPERABLE.

Condition: One [required] inverter inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more AC electrical power distribution subsystems inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Page 36 Specification LCO Requirements and Condition Condition on Use 3.8.9.B LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more AC vital buses inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

Condition: One or more DC electrical power distribution subsystems inoperable.

Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 37 Specification LCO Requirements and Condition Condition on Use 3.3.6.C (analog)

LCO: [Four] channels of Loss of Voltage Function and [four] channels of Degraded Voltage Function auto-initiation instrumentation per DG shall be OPERABLE.

Condition: One or more Functions with more than two channels inoperable.

Licensee must justify that more than two channels per bus inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of.

3.4.9.B LCO: The pressurizer shall be OPERABLE Condition: One [required] group of pressurizer heaters inoperable.

Pressurizer is typically not modeled in the PRA. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 38 Specification LCO Requirements and Condition Condition on Use 3.4.10.A LCO: [Two] pressurizer safety valves shall be OPERABLE with lift settings > [2475] psia and <

[2525] psia.

Condition: One pressurizer safety valve inoperable The Applicable Safety Analysis section of the Bases states that the accident analysis assumes all PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM31].

3.4.11.E LCO: Each Power Operated Relief Valve (PORV) and associated block valve shall be OPERABLE Condition: Two PORVs inoperable and incapable of being manually cycled.

Licensee must justify that all PORVs inoperable and incapable of being cycled is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM32].

3.4.11.F LCO: Each PORV and associated block valve shall be OPERABLE Condition: Two block valves inoperable Licensee must justify that all block valves inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM33].

3.4.14.C LCO: Leakage from each reactor coolant system (RCS) pressure isolation valve (PIV) shall be within limits.

Condition: Shutdown Cooling System autoclosure interlock function inoperable.

Licensee must justify that applying a RICT to the action to isolate the affected penetration is equivalent to isolating a Containment Isolation Valve and is acceptable[BM34]

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 39 Specification LCO Requirements and Condition Condition on Use 3.5.1.B LCO: [Four] Safety Injection Tanks (SIT) shall be OPERABLE.

Condition: One SIT inoperable The Applicable Safety Analysis Bases state that three SITs are required to inject to meet the ECCS acceptance criteria and the contents of one SIT are assumed lost through the break.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM35].

3.5.2.D LCO: Two ECCS trains shall be OPERABLE.

Condition: Less than 100% of the ECCS flow equivalent to a single OPERABLE train available.

Licensee must justify that one or more ECCS trains inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 40 Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE. Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock mechanism.

Licensee must justify that an inoperable containment air lock is not a condition in which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.A LCO: One high pressure safety injection (HPSI) train shall be OPERABLE.

Condition: Required HPCI train inoperable (Mode

4)

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM36].

3.5.4.A LCO: The Refueling Water Tank (RWT) shall be OPERABLE.

Condition: RWT inoperable due to boron concentration or borated water temperature not within limits.

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM37].

3.5.4.B LCO: The Refueling Water Tank (RWT) shall be OPERABLE.

Condition: RWT inoperable other than Condition A (above).

Licensee must justify that it is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM38].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 41 Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be OPERABLE.

Condition: One or more containment air locks inoperable for reasons other than an inoperable door or inoperable interlock Licensee must justify that an inoperable containment air lock is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM39].

3.6.3.B LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with two [or more] containment isolation valves inoperable [for reasons other than leakage limits Licensee must justify that all inoperable containment isolation valves on a penetration is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM40].

3.6.3.C LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with one containment isolation valve inoperable.

Licensee must justify that an inoperable containment isolation valve on a penetration is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM41].

3.6.3.D LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more secondary containment bypass leakage [or purge valve leakage] not within limit.

Licensee must justify that purge valve leakage is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM42].

3.6.3.E LCO: Each containment isolation valve shall be OPERABLE.

Condition: One or more penetration flow paths with one or more containment purge valves not within purge valve leakage limits.

Licensee must justify that purge valve leakage is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM43].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 42 Specification LCO Requirements and Condition Condition on Use 3.6.6A LCO: Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit taken for iodine removal by the Containment Spray System)

Condition A: One containment spray train inoperable.

Condition C: One containment cooling train inoperable.

Condition D: One containment spray and one containment cooling train inoperable.

Condition E: Two containment cooling trains inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.6B LCO: Containment Spray and Cooling Systems (Atmospheric and Dual) (Credit not taken for iodine removal by the Containment Spray System)

Condition A: One containment spray train inoperable.

Condition B: One containment cooling train inoperable.

Condition C: Two containment spray trains inoperable.

Condition D: One containment spray train and one containment cooling train inoperable.

Condition E: Two containment cooling trains inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.7.4.B LCO: [Two] Atmospheric Dump Valve (ADV) lines shall be OPERABLE. Condition: Two or more [required] ADV lines inoperable.

Licensee must justify that two or more inoperable ADVs is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM44].

3.7.6.A LCO: The Condensate Storage Tank (CST) shall be OPERABLE.

Condition: CST inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM45].

Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Page 43 Specification LCO Requirements and Condition Condition on Use 3.8.1.E LCO: The following AC electrical sources shall be OPERABLE:

Condition: Two DGs inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM46].