ML11287A128

Calvert Cliffs, Units 1 and 2 - Technical Specification Bases, Revisions 40 Through 43, Section B 3.0 - Limiting Condition for Operation (LCO) Applicability

ML11287A128
Person / Time
Site:	Calvert Cliffs
Issue date:	10/04/2011
From:	Calvert Cliffs, Constellation Energy Group, EDF Group
To:	Office of Nuclear Reactor Regulation
References
Download: ML11287A128 (25)

Text

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-1 Revision 35 LCOs Limiting Condition for Operation (LCO) 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated. LCO 3.0.1 Limiting Condition for Operation 3.0.1 establishes the Applicability statement within each individual Specification

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 Limiting Condition for Operation 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 when 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: 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 for meeting

the LCO. 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, permit t ing continued operation of the unit, that are not further restricted by the Completion Time. In this case, LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-2 Revision 2 compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO

is met or is no longer applicable, unless otherwise stated

in the individual Specifications.

The nature of some Required Actions of some Conditions

necessitates that, once the Condition is entered, the

Required Actions must be completed even though the

associated Conditions no longer exist. The individual LCO's

ACTIONS specify the Required Actions where this is the case (e.g., LCO 3.4.3).

The Completion Times of the Required Actions are also

applicable when a system or component is removed from

service intentionally. The reasons for intentionally

relying on the ACTIONS include, but are not limited to, performance of Surveillance Requirements (SR s), preventive maintenance, corrective maintenance, or investigation of

operational problems. Entering ACTIONS for these reasons

must be done in a manner that does not compromise safety.

Intentional entry into ACTIONS should not be made for

operational convenience. Additionally, if intentional entry

into ACTIONS would result in redundant equipment being inoperable, alternatives should be used

. Doing so limits the time both subsystems/trains of a safety function are

inoperable and limits the time conditions exist that may result in LCO 3.0.3 being entered. Individual

Specifications may state a time limit for performing an SR when equipment is removed from service or bypassed for

testing. In this case, the Completion Times of the Required

Actions are applicable when this time limit expires if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter

a MODE or other specified condition in which another

Specification becomes applicable. In this case, the

Completion Times of the associated Required Actions would

apply when the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-3 Revision 2 LCO 3.0.3 Limiting Condition for Operation 3.0.3 establishes the actions that must be implemented when an LCO is not met and: a. An associated Required Action and Completion Time is not met and no other Condition applies; or b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition

of the unit. Sometimes, possible combinations of

Conditions are such that entering LCO 3.0.3 is

warranted; in such cases, the ACTIONS specifically

state a Condition corresponding to such combinations

and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE

, or other specified condition when operation cannot be maintained within the limits for safe

operation , as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that

permits routine

, voluntary removal of redundant systems or components from service in lieu of other alternatives that

would not result in redundant systems or components being

inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an

orderly shutdown before initiating a change in unit

operation. This includes time to permit the operator to

coordinate the reduction in electrical generation with the

load dispatcher to ensure the stability and availability of

the electrical grid. The time limits specified to reach

lower MODEs of operation permit the shutdown to proceed in a controlled and orderly manner well within the specified maximum cooldown rate and capabilities of the unit, assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that

could challenge safety systems under the conditions to which this Specification applies. The use and interpretation of

specified times to complete the actions of LCO 3.0.3 are

consistent with the discussion of Section 1.3, Completion

Times.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-4 Revision 2 A unit shutdown required in accordance with LCO 3.0.3 may be terminated

, and LCO 3.0.3 exited

, if any of the following occurs: a. The LCO has been met. b. A Condition exists for which the Required Actions have been performed. c. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from that point in time the Condition is initially entered

, and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for

the unit to be in MODE 5 when a shutdown is required during

MODE 1 operation. If the unit is in a lower MODE of

operation when a shutdown is required, the time limit for

reaching the next lower MODE applies. If a lower MODE is

reached in less time than allowed, however, the total

allowable time to reach MODE 5, or other applicable MODE, is

not reduced. For example, if MODE 3 is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the time allowed for reaching MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for reaching MODE 4 is not reduced

from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if

remedial measures are completed that would permit a return

to MODE 1, a penalty is not incurred by having to reach a

lower MODE of operation in less than the total time allowed.

In MODEs 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The

requirements of LCO 3.0.3 do not apply in MODEs 5 and 6 , because the unit is already in the most restrictive

Condition required

.

The requirements of LCO 3.0.3 do not apply in other

specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4)

, because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances

where requiring a unit shutdown, in accordance with

LCO 3.0.3, would not provide appropriate remedial measures

for the associated condition of the unit. An example of

this is in LCO 3.7.13

. Limiting Condition for Operation 3.7.13 has an Applicability of "During movement of LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-5 Revision 26 irradiated fuel assemblies in the spent fuel pool."

Therefore, this LCO can be applicable in any or all MODEs.

If the LCO and the Required Actions of LCO 3.7.13 are not

met while in MODE 1, 2, or 3, there is no safety benefit to

be gained by placing the unit in a shutdown condition. The

Required Action of LCO 3.7.13 of "Suspend movement of irradiated fuel assemblies in spent fuel pool" is the appropriate Required Action to complete in lieu of the

actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 Limiting Condition for Operation 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It

allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met

, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

Limiting Condition for Operation 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of

time in a MODE or other specified condition provides an

acceptable level of safety for continued operation. This is

without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made

in accordance with the provisions of the Required Actions.

Limiting Condition for Operation 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-6 Revision 26 The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and contain example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

Limiting Condition for Operation 3.0.4.b may be used with single, or multiple systems and components unavailable.

NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-7 Revision 26 The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

Limiting Condition for Operation 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., Pressurizer), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-8 Revision 26 result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillance s do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any SRs that have not be en performed on inoperable equipment.

However, SRs must be met to ensure OPERABILITY prior to

declaring the associated equipment OPERABLE (or variable

within limits) and restoring compliance with the affected LCO. LCO 3.0.5 Limiting Condition for Operation 3.0.5 establishes the allowance for restoring equipment to service under

administrative controls when it has been removed from

service or declared inoperable to comply with ACTIONS. The

sole purpose of this Specification is to provide an

exception to LCO 3.0.2 [e.g., to not comply with the

applicable Required Action(s)]

to allow the performance of required testing to demonstrate: a. The OPERABILITY of the equipment being returned to service; or b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service (in conflict with the requirements of

the ACTIONS) is limited to the time absolutely necessary to

perform the required testing to demonstrate OPERABILITY.

This Specification does not provide time to perform any

other preventive or corrective maintenance.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-9 Revision 26 An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment

isolation valve that has been closed to comply with Required

Actions and must be reopened to perform the required

testing. An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out

of the tripped condition to prevent the trip function from

occurring during the performance of required testing on

another channel in the other trip system. A similar example

of demonstrating the OPERABILITY of other equipment is

taking an inoperable channel or trip system out of the

tripped condition to permit the logic to function and

indicate the appropriate response during the performance of required testing on another channel in the same trip system.

LCO 3.0.6 Limiting Condition for Operation 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO

specified in the Technical Specifications. This exception

is provided because LCO 3.0.2 would require the Conditions

and Required Actions of the associated inoperable supported

system LCO to be entered solely due to the inoperability of

the support system. This exception is justified because the

actions required to ensure the unit is maintained in a safe

condition are specified in the support system LCO's Required

Actions. These Required Actions may include entering the

supported system's Conditions and Required Actions or may

specify other Required Actions.

When a support system is inoperable and there is an LCO specified for it in the Technical Specification, the supported system(s) are required to be declared inoperable

if they are determined to be inoperable as a result of the

support system inoperability. However, it is not necessary

to enter into the supported systems' Conditions and Required

Actions unless directed to do so by the support system's

Required Actions. The potential confusion and inconsistency

of requirements related to the entry into multiple support

and supported systems' LCOs' and Required Actions are

eliminated by providing all the actions necessary to ensure

the unit is maintained in a safe condition in the support

system's Required Actions.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-10 Revision 26 However, there are instances where a support system's

Required Action may either direct a supported system to be

declared inoperable or direct entry into Conditions and

Required Actions for the supported system. This may occur

immediately or after some specified delay to perform some other Required Action. Regardless of whether it is immediate or after some delay, 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.

Specification 5.5.15, "Safety Function Determination Program (SFDP)," ensures loss of safety function is detected and

appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety

function exists. Additionally, other limitations, remedial

actions, or compensatory actions may be identified as a

result of the support system inoperability and corresponding

exception to entering supported system Conditions and

Required Actions. The SFDP implements the requirements of

LCO 3.0.6.

Cross-train checks to identify a loss of safety function for those support systems supporting 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. A loss of safety function may exist when a

support system is inoperable, and: a. A required system redundant to system(s) supported by the inoperable support system is also inoperable; or EXAMPLE B3.0.6-1 If System 2 of Train A is inoperable, and System 5 of Train B is inoperable, a loss of safety function

exists in supported System 5.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-11 Revision 26

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or EXAMPLE B3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11, which is in turn supported by System 5.

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also

inoperable.

EXAMPLE B3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function

exists in Systems 2, 4, 5, 8, 9, 10, and 11.

TRAIN A TRAIN B System 8 System 8 System 4 System 4 System 9 System 9 System 2 System 2 System 10 System 10 System 5 System 5 System 11 System 11System 1 System 1 System 12 System 12 System 6 System 6 System 13 System 13 System 3 System 3 System 14 System 14 System 7 System 7 System 15 System 15 If this evaluation determines that a loss of 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 Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-12 Revision 35 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. Special Test Exception (STE)

LCOs 3.1.7, 3.1.8, and 3.4.17 allow specific Technical Specification requirements to be changed to permit

performances of these special tests and operations, which

otherwise could not be performed if required to comply with

these Technical Specifications. Unless otherwise specified, all the other Technical Specification 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 STE LCO represents a condition not necessarily in compliance with the normal requirements of

the Technical Specification. Compliance with STE LCOs is

optional. A special operation may be performed either under

the provisions of the appropriate STE LCO or under the other

applicable Technical Specification requirements. If it is

desired to perform the special operation under the

provisions of the STE LCO, the requirements of the STE LCO shall be followed.

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 seismic-designated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications in the Technical Requirements Manual (TRM). The snubber requirements do not meet the criteria in 10 CFR LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-13 Revision 35 50.36(d)(2)(ii), and, as such, are appropriate for control by the TRM.

The allowances in this LCO apply only to seismic snubbers.

In adding the LCO to the Technical Specifications, the Nuclear Regulatory Commission (NRC) based their decision on a risk analysis. That analysis considered an earthquake-induced loss-of-offsite power and did not consider other dynamic loading, such as waterhammer. Therefore, the LCO is also applicable to snubbers that have the dual function of seismic and other dynamic loading if the train is not inoperable for any reason other than a lack of seismic support. If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO 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 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 of a single train system. The supported system must not be inoperable for any reason other than a lack of seismic support. The LCO allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. For example, if multiple inoperable snubbers affect separate trains of a system or one inoperable snubber affects multiple trains of a system, LCO 3.0.8.b is applicable. The supported system must not be inoperable for any reason other than a lack of seismic LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-14 Revision 35 support. The LCO allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

LCO 3.0.8 requires that risk be assessed and managed.

Industry and the 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 must be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance of any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

The NRC placed several conditions on the use of LCO 3.0.8:

a. When LCO 3.0.8.a is used, one auxiliary feedwater (AFW) train not associated with the inoperable snubber must be available for core cooling.

b. When LCO 3.0.8.b is used, either one AFW train not associated with the inoperable snubber or some alternative means of cooling the core must be available (e.g., once-through core cooling).

c. When the provisions of LCO 3.0.8 are used, at least one train of the supported system must be capable of performing the required safety or support function(s) for postulated loads other than seismic loads.

d. A record of the design function of the inoperable snubber (i.e., seismic versus non-seismic), the implementation of any of these conditions, and the associated plant configuration shall all be available on a recoverable basis for NRC inspection.

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-15 Revision 35

e. When entering LCO 3.0.8, risk must be assessed and managed. The Maintenance Rule program complying with 10 CFR 50.65(a)(4) satisfies this condition.

LCO 3.0.9 L CO 3.0.9 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of

providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not

explicitly described in Technical Specifications, that

support the performance of the safety function of systems

described in the Technical Specifications. This LCO states

that the supported system is not considered to be inoperable

solely due to required barriers not capable of performing

their related support function(s) under the described

conditions. LCO 3.0.9 allows 30 days before declaring the

supported system(s) inoperable and the LCO(s) associated

with the supported system(s) not met. A maximum time is

placed on each use of this allowance to ensure that as

required barriers are found or are otherwise made

unavailable, they are restored. However, the allowable

duration may be less than the specified maximum time based

on the risk assessment.

If the allowed time expires and the barriers are unable to

perform their related support function(s), the supported

system's LCO(s) must be declared not met and the Conditions

and Required Actions entered in accordance with LCO 3.0.2.

This provision does not apply to barriers which support

ventilation systems or to fire barriers. The Technical Specifications for ventilation systems provide specific Conditions for inoperable barriers. Fire barriers are

addressed by other regulatory requirements and associated

plant programs. This provision does not apply to barriers

which are not required to support system OPERABILITY (see

NRC Regulatory Issue Summary 2001-09, "Control of Hazard

Barriers," dated April 2, 2001).

LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-16 Revision 35 The provisions of LCO 3.0.9 are justified because of the low risk associated with required barriers not being capable of

performing their related support function. This provision

is based on consideration of the following initiating event

categories:

• Loss of coolant accidents;

• High energy line breaks;

• Feedwater line breaks;

• Internal flooding;

• External flooding;

• Turbine missile ejection; and

• Tornado or high wind.

The risk impact of the barriers which cannot perform their

related support function(s) must be addressed pursuant to

the risk assessment and management provision of the

Maintenance Rule, 10 CFR 50.65(a)(4), and the associated

implementation guidance, Regulatory Guide 1.182, "Assessing

and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for

Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants." This guidance provides for the consideration of

dynamic plant configuration issues, emergent conditions, and

other aspects pertinent to plant operation with the barriers

unable to perform their related support function(s). These

considerations may result in risk management and other

compensatory actions being required during the period that

barriers are unable to perform their related support

function(s).

LCO 3.0.9 may be applied to one or more trains or subsystems

of a system supported by barriers that cannot provide their

related support function(s), provided that risk is assessed

and managed (including consideration of the effects on Large

Early Release and from external events). If applied

concurrently to more than one train or subsystem of a

multiple train or subsystem supported system, the barriers

supporting each of these trains or subsystems must provide

their related support function(s) for different categories

of initiating events. For example, LCO 3.0.9 may be applied

for up to 30 days for more than one train of a multiple LCO Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-17 Revision 35 train supported system if the affected barrier for one train protects against internal flooding and the affected barrier

for the other train protects against tornado missiles. In

this example, the affected barrier may be the same physical

barrier but serve different protection functions for each

train. If during the time that LCO 3.0.9 is being used, the

required OPERABLE train or subsystem becomes inoperable, it

must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, the train(s) or subsystem(s) supported by

barriers that cannot perform their related support

function(s) must be declared inoperable and the associated

LCOs declared not met. This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period provides time to

respond to emergent conditions that would otherwise likely

lead to entry into LCO 3.0.3 and a rapid plant shutdown, which is not justified given the low probability of an

initiating event which would require the barrier(s) not

capable of performing their related support function(s).

During this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the plant risk associated with

the existing conditions is assessed and managed in

accordance with 10 CFR 50.65(a)(4).

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-18 Revision 35 SRs Surveillance Requirement 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.1 Surveillance Requirement 3.0.1 establishes that SRs must be met during the MODEs or other specified conditions in the

Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This

Specification is to ensure that surveillance tests are

performed to verify the OPERABILITY of systems and

components, and that variables are within specified limits.

Failure to meet a SR within the specified Frequency, in

accordance with SR 3.0.2, constitutes a failure to meet an

LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this

Specification, however, is to be construed as implying that

systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the SRs; or b. The requirements of the surveillance test(s) are known to not be met between required surveillance test performances.

Surveillance tests do not have to be performed when the unit is in a MODE or other specified condition for which the

requirements of the associated LCO are not applicable, unless otherwise specified. The SRs associated with a STE are only applicable when the STE is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this

case, the unplanned event may be credited as fulfilling the

performance of the SR. This allowance includes those SRs

whose performance is normally precluded in a given MODE or

other specified condition.

SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-19 Revision 35 Surveillance tests, including surveillance tests invoked by Required Actions, do not have to be performed on inoperable

equipment, because the ACTIONS define the applicable

remedial measures. Surveillance tests have to be performed

in accordance with SR 3.0.2 prior to returning equipment to

OPERABLE status.

Upon completion of maintenance, appropriate post-maintenance

testing is required to declare equipment OPERABLE. This

includes ensuring applicable surveillance tests pass and

their most recent performance is in accordance with

SR 3.0.2. Post-maintenance testing may not be possible in

the current MODE or other specified conditions in the

Applicability due to the necessary unit parameters not

having been established. In these situations, the equipment

may be considered OPERABLE provided testing has been

satisfactorily completed to the extent possible and the

equipment is not otherwise believed to be incapable of

performing its function. This will allow operation to

proceed to a MODE or other specified condition where other

necessary post-maintenance tests can be completed. Some examples of this process are: a. Auxiliary feedwater pump turbine maintenance during refueling that requires testing at steam pressures

> 800 psi. However, if other appropriate testing is

satisfactorily completed, the Auxiliary Feedwater

System can be considered OPERABLE. This allows startup

and other necessary testing to proceed until the plant

reaches the steam pressure required to perform the

testing. b. High pressure safety injection maintenance during shutdown that requires system functional tests at a

specified pressure. Provided other appropriate testing

is satisfactorily completed, startup can proceed with high pressure safety injection considered OPERABLE.

This allows operation to reach the specified pressure to complete the necessary post-maintenance testing.

SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-20 Revision 35 SR 3.0.2 Surveillance Requirement 3.0.2 establishes the requirements for meeting the specified Frequency for surveillance tests and any Required Action with a Completion Time that requires

the periodic performance of the Required Action on a "once

per . . ." interval.

Surveillance Requirement 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension

facilitates surveillance test scheduling and considers plant

operating conditions that may not be suitable for conducting

the surveillance test (e.g., transient conditions or other

ongoing surveillance test or maintenance activities).

The 25% extension does not significantly degrade the

reliability that results from performing the surveillance

test at its specified Frequency. This is based on the

recognition that the most probable result of any particular

surveillance test being performed is the verification of

conformance with the SRs. The exceptions to SR 3.0.2 are

those surveillance tests for which the 25% extension of the

interval specified in the Frequency does not apply. These

exceptions are stated in the individual Specifications. An

example of where SR 3.0.2 does not apply is the Containment

Leakage Rate Testing Program.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that

requires performance on a "once per . . ." basis. The 25%

extension applies to each performance after the initial

performance. The initial performance of the Required

Action, whether it is a particular surveillance test or some

other remedial action, is considered a single action with a

single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or

accomplishes the function of the inoperable equipment in an

alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly, merely as an operational convenience to extend

surveillance test intervals (other than those consistent SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-21 Revision 35 with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 Surveillance Requirement 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an

affected variable outside the specified limits when a surveillance test has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up

to the limit of the specified Frequency, whichever is

greater, applies from when it is discovered that the

surveillance test has not been performed in accordance with

SR 3.0.2, and not at the time that the specified Frequency

was not met.

A risk evaluation shall be performed for any Surveillance

delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be

managed.

This delay period provides an adequate time to complete missed surveillance tests. This delay period permits the

completion of a surveillance test before complying with

Required Actions or other remedial measures that might

preclude completion of the surveillance test.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of

personnel, the time required to perform the surveillance

test, the safety significance of the delay in completing the

surveillance test, and the recognition that the most

probable result of any particular surveillance test being

performed is the verification of conformance with the

requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating

situations, or requirements of regulations (e.g., prior to

entering MODE 1 after each fuel loading, or in accordance

with 10 CFR Part 50, Appendix J, as modified by approved

exemptions, etc.) is discovered to not have been performed

when specified, SR 3.0.3 allows for the full delay period of

up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-22 Revision 35 missed Surveillance should be performed at the first reasonable opportunity.

Surveillance Requirement 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that

become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is

expected to be an infrequent occurrence. Use of the delay

period established by SR 3.0.3 is a flexibility that is not

intended to be used as an operational convenience to extend

surveillance test intervals.

While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is

expected that the missed Surveillance will be performed at

the first reasonable opportunity. The determination of the

first reasonable opportunity should include consideration of

the impact on plant risk (from delaying the Surveillance, as

well as any plant configuration changes required or shutting

the plant down to perform the Surveillance) and impact on

any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required

to perform the Surveillance. This risk impact should be

managed through the program in place to implement

10 CFR 50.65(a)(4) and its implementation guidance, NRC

Regulatory Guide 1.182, "Assessing and Managing Risk Before

Maintenance Activities at Nuclear Power Plants." This

Regulatory Guide addresses consideration of temporary and

aggregate risk impacts, determination of risk management

action thresholds, and risk management action up to and

including plant shutdown. The missed Surveillance should be

treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and

rigor of the evaluation should be commensurate with the

importance of the component. Missed Surveillances for

important components should be analyzed quantitatively. If

the results of the risk evaluation determine the risk

increase is significant, this evaluation should be used to

determine the safest course of action. All missed SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-23 Revision 35 Surveillances will be placed in the licensee's Corrective Action Program.

If a surveillance test is not completed within the allowed

delay period, the equipment is considered inoperable or the

variable is considered outside the specified limits, and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the

delay period. If a surveillance test fails within the delay

period, the equipment is inoperable or the variable is

outside the specified limits, and the Completion Times of

the Required Actions for the applicable LCO Conditions begin

immediately upon the failure of the surveillance test.

Completion of the surveillance test within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 Surveillance Requirement 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE

or other specified Condition in the Applicability.

This Specification ensures system and component OPERABILITY

requirements and variable limits are met before entry into

MODEs or other specified conditions in the Applicability for

which these systems and components ensure safe operation of

the unit. The provisions of this Specification should not

be interpreted as endorsing the failure to exercise the good

practice of restoring systems or components to OPERABLE

status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not

met due to Surveillance not being met in accordance with

LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or

other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or

outside its specified limits, the associated SR(s) are not

required to be performed, per SR 3.0.1, which states that SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-24 Revision 35 Surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not

apply to the associated SR(s) since the requirement for the

SR(s) to be performed is removed. Therefore, failing to

perform the Surveillance(s) within the specified Frequency

does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability.

However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not)

apply to MODE or other specified condition changes.

Surveillance Requirement 3.0.4 does not restrict changing

MODES or other specified conditions of the Applicability

when a Surveillance has not been performed within the

specified Frequency, provided the requirement to declare the

LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability

that are required to comply with ACTIONS. In addition, the

provisions of SR 3.0.4 shall not prevent changes in MODES or

other specified conditions in the Applicability that result

from any unit shutdown. In this context, a unit shutdown is

defined as a change in MODE or other specified condition in

the Applicability associated with transitioning from MODE 1

to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to

MODE 5.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not

necessary. The specific time frames and conditions

necessary for meeting the SRs are specified in the

Frequency, in the Surveillance, or both. This allows

performance of Surveillances when the prerequisite

condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance

or completion of a Surveillance. A Surveillance that could

not be performed until after entering the LCO's

Applicability, would have its Frequency specified such that

it is not "due" until the specific conditions needed are

met. Alternately, the Surveillance may be stated in the

form of a Note, as not required (to be met or performed)

until a particular event, condition, or time has been SR Applicability B 3.0 BASES CALVERT CLIFFS - UNITS 1 & 2 B 3.0-25 Revision 35 reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.