https://www.nrc.gov/docs/ML2401/ML24016A270.pdf

text

PWROG-9, Rev. 0 TSTF-585, Rev. 3

NUREGs Affected:

Revise LCO 3.0.3 to Require Managing Risk

Technical Specifications Task Force

Improved Standard Technical Specifications Change Traveler

1430 1431 1432 1433 1434

Classification: 1) Technical Change Recommended for CLIIP?: Yes

Correction or Improvement: Improvement NRC Fee Status: Not Exempt

Benefit: Avoids a Plant Shutdown Changes Marked on ISTS Rev 5.0

2194

PWROG RISD & PA (if applicable): PA-LSC-1708 RS-2019-005

See attached.

Revision History

OG Revision 0 Revision Status: Closed

Original Issue

Revision Description:

Revision Proposed by: PWROG

Owners Group Review Information

Date Originated by OG: 25-Feb-21

Owners Group Comments

(No Comments)

Owners Group Resolution: Approved Date: 19-Mar-21

TSTF Review Information

TSTF Received Date: 19-Mar-21 Date Distributed for Review 19-Mar-21

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 05-Apr-21

TSTF Revision 1 Revision Status: Closed

The draft traveler was renamed and revised based on NRC comments.

Revision Description:

Revision Proposed by: TSTF

12-Dec-23

granted. All other use without written permission is prohibited.

DRAFT

PWROG-9, Rev. 0 TSTF-585, Rev. 3

TSTF Revision 1 Revision Status: Closed

Owners Group Review Information

Date Originated by OG: 26-Oct-21

Owners Group Comments

(No Comments)

Owners Group Resolution: Approved Date: 11-Nov-21

TSTF Review Information

TSTF Received Date: 11-Nov-21 Date Distributed for Review 11-Nov-21

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 30-Nov-21

TSTF Revision 2 Revision Status: Closed

The traveler was revised to address NRC comments:

- Certain specifications were revised to require a plant shutdown instead of entering LCO 3.0.3.

- The changes to LCO 3.0.3 were minimized.

- The justification was expanded to provide more information on applying the Maintenance Rule guidance to

emergent conditions.

- The justification was expanded to discuss transition between LCO 3.0.3.a and LCO 3.0.3.b.

Revision Description:

Revision Proposed by: TSTF

Owners Group Review Information

Date Originated by OG: 02-Feb-23

Owners Group Comments

(No Comments)

Owners Group Resolution: Approved Date: 17-Feb-23

TSTF Review Information

TSTF Received Date: 17-Feb-23 Date Distributed for Review 17-Feb-23

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 06-Mar-23

NRC Review Information

NRC Received Date: 06-Mar-23

12-Dec-23

granted. All other use without written permission is prohibited.

DRAFT

PWROG-9, Rev. 0 TSTF-585, Rev. 3

Affected Technical Specifications

TSTF Revision 2 Revision Status: Closed

Final Resolution: NRC Requests Changes: TSTF Will Revise

TSTF Revision 3 Revision Status: Active

Based on feedback from the NRC, TSTF-585 was significantly revised. The traveler was renamed from

"Provide an Alternative to the LCO 3.0.3 One-Hour Preparation Time" to "Revise LCO 3.0.3 to Require

Managing Risk."

LCO 3.0.3 was revised to require a risk assessment and implementation of risk management actions within 6

hours of entry into LCO 3.0.3. If the risk assessment determines that the risk of continuing plant operaiton is

acceptable, the risk management actions are implemented, and the entry into LCO 3.0.3 was not planned, 24

hours from entry into LCO 3.0.3 is provided before initiating a plant shutdown. Otherwise, an immediate

shutdown is must be initiated at the end of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period.

Revision Description:

Revision Proposed by: TSTF

Owners Group Review Information

Date Originated by OG: 23-Oct-23

Owners Group Comments

(No Comments)

Owners Group Resolution: Approved Date: 06-Nov-23

TSTF Review Information

TSTF Received Date: 27-Nov-23 Date Distributed for Review 27-Nov-23

TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 12-Dec-23

LCO 3.0.3 LCO Applicability

LCO 3.0.3 Bases LCO Applicability

Action 3.8.4.E NUREG(s)- 1430 1431 1432 1433 1434

Only

Change Description: New Action

DC Sources - Operating

Action 3.8.4.E Bases NUREG(s)- 1430 1431 1432 1433 1434

Only

Change Description: New Action

DC Sources - Operating

Action 3.7.2.B Main Steam Isolation Valves (MSIVs) NUREG(s)- 1430 1431 1432 Only

Action 3.7.2.B Bases Main Steam Isolation Valves (MSIVs) NUREG(s)- 1430 1431 1432 Only

12-Dec-23

granted. All other use without written permission is prohibited.

DRAFT

PWROG-9, Rev. 0 TSTF-585, Rev. 3

Action 3.8.4.D DC Sources - Operating NUREG(s)- 1430 1431 1432 Only

Action 3.8.4.D Bases DC Sources - Operating NUREG(s)- 1430 1431 1432 Only

Action 3.8.9.E Distribution Systems - Operating NUREG(s)- 1430 1431 1432 Only

Action 3.8.9.E Bases Distribution Systems - Operating NUREG(s)- 1430 1431 1432 Only

Action 3.1.6.B APSR Alignment Limits NUREG(s)- 1430 Only

Action 3.1.6.B Bases APSR Alignment Limits NUREG(s)- 1430 Only

Action 3.6.10.C HIS (Ice Condenser) NUREG(s)- 1431 Only

Action 3.6.10.C Bases HIS (Ice Condenser) NUREG(s)- 1431 Only

Action 3.8.4.F DC Sources - Operating NUREG(s)- 1433 1434 Only

Action 3.8.4.F Bases DC Sources - Operating NUREG(s)- 1433 1434 Only

Action 3.8.9.F Distribution Systems - Operating NUREG(s)- 1433 1434 Only

Action 3.8.9.F Bases Distribution Systems - Operating NUREG(s)- 1433 1434 Only

Action 3.8.4.G DC Sources - Operating NUREG(s)- 1434 Only

Action 3.8.4.G Bases DC Sources - Operating NUREG(s)- 1434 Only

Action 3.8.5.F Distribution Systems - Operating NUREG(s)- 2194 Only

Action 3.8.5.F Bases Distribution Systems - Operating NUREG(s)- 2194 Only

12-Dec-23

granted. All other use without written permission is prohibited.

DRAFT

TSTF-585, Rev. 3

Page i

Table of Contents

1. SUMMARY DESCRIPTION ......................................................................................................... 1

2. DETAILED DESCRIPTION .......................................................................................................... 1

2.1. Background .................................................................................................................... 1

2.2. Current Technical Specifications Requirements ............................................................ 2

2.3. Reason for the Proposed Change .................................................................................... 4

2.4. Description of the Proposed Change .............................................................................. 5

3. TECHNICAL EVALUATION ....................................................................................................... 9

3.1. LCO 3.0.3 Change Overview ......................................................................................... 9

3.1.1. The Proposed Change is Consistent with the Regulations ........................................ 9

3.1.2. The Proposed Change Improves Plant Safety ......................................................... 10

3.1.3. The Proposed Change Leverages Existing Risk Management Tools ..................... 11

3.1.3.1. 10 CFR 50.65(a)(4) .......................................................................................... 11

3.2. LCO 3.0.3 Detailed Justification .................................................................................. 14

3.2.1. Time to Assess and Manage Risk and Implement Risk Management Actions ...... 14

3.2.2. Plant Operation May Continue if Risk is Acceptable ............................................. 14

3.2.3. Plant Operation May Continue if the LCO 3.0.3 Entry is Unplanned .................... 15

3.2.4. Basis for the 24-Hour Period .................................................................................. 15

3.3. LCO 3.0.3 Editorial Changes ....................................................................................... 17

3.4. Other TS Changes ........................................................................................................ 17

3.4.1. Other TS Evaluation ............................................................................................... 17

3.4.2. Other TS Changes ................................................................................................... 18

3.4.2.1. NUREG-1430, TS 3.1.6, "AXIAL POWER SHAPING ROD (APSR)

Alignment Limits" ............................................................................................ 18

3.4.2.2. NUREG-1431, TS 3.6.10, "Hydrogen Ignition System (HIS)" ....................... 19

3.4.2.3. NUREG-1430, NUREG-1431, and NUREG-1432, TS 3.7.2, "Main Steam

Isolation Valves (MSIVs)" ............................................................................... 19

3.4.2.4. NUREG-1430 through NUREG-1434 TS 3.8.4, "DC Sources - Operating" ... 19

3.4.2.5. NUREG-1430 through NUREG-1434 TS 3.8.9, and NUREG-2194 TS 3.8.5,

"Distribution Systems - Operating" .................................................................. 20

3.5. TS Bases Changes ........................................................................................................ 20

3.6. Conclusion .................................................................................................................... 21

4. REGULATORY EVALUATION ................................................................................................ 21

5. REFERENCES .............................................................................................................................. 22

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TSTF-585, Rev. 3

Page 1

1. SUMMARY DESCRIPTION

The proposed change revises Limiting Condition for Operation (LCO) 3.0.3 to require assessing

and managing plant risk whenever LCO 3.0.3 is entered. Six hours are provided to perform the

risk assessment and to implement any necessary risk management actions. If the assessment

determines that the risk of continued plant operation is acceptable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into

LCO 3.0.3 is provided to prepare for a plant shutdown, to perform repairs, or to request relief

from the NRC. If the assessment determines that the risk of continued plant operation is not

acceptable, then initiation of actions to shut down the plant is required. The proposed change

also revises or adds some Technical Specifications (TS) Required Actions to require a plant

shutdown instead of entry into LCO 3.0.3. The proposed change affects the Standard Technical

Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433,

NUREG-1434, and NUREG-21941

.

2. DETAILED DESCRIPTION

2.1. Background

LCO 3.0.3 requires a plant shutdown under three conditions:

1. An LCO is not met, and the associated Actions are not met;

2. An LCO is not met, and an associated Action is not provided; or

3. An LCO is not met, and LCO 3.0.3 entry is directed by the associated Actions.

LCO 3.0.3 requires initiation of actions to shut down the plant within one hour if any of these

conditions are met.

LCO 3.0.3 entries can be explicit or implicit. Explicit LCO 3.0.3 entries are directed by a

Required Action in a specification, which typically states, "Enter LCO 3.0.3," with a Completion

Time of "Immediately." Implicit LCO 3.0.3 entries result from a specification not providing an

Action that reflects a failure to meet the LCO. The most common use of implicit LCO 3.0.3

entries is to not include an Action for more than one inoperable train or subsystem in a TS that

requires multiple trains or subsystems to be operable. For example, a circulating water system

1NUREG-1430 provides the STS for Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the

BWR/2, BWR/3, and, in some cases, BWR/5 designs.

NUREG-1434 provides the STS for the BWR/6 plant design, and is representative, in some

cases, of the BWR/5 plant design.

NUREG-2194 provides the STS for Westinghouse Advanced Passive (AP) 1000 plant designs.

DRAFT

TSTF-585, Rev. 3

Page 2

TS could require two trains to be operable but only provide an Action for one inoperable train. If

both trains are inoperable, LCO 3.0.3 is applicable.

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.36(c)(2), "Limiting

Conditions for Operation," states, "When a limiting condition for operation of a nuclear reactor is

not met, the licensee shall shut down the reactor or follow any remedial action permitted by the

technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by

providing a requirement to shut down the reactor if an LCO is not met and the TS does not

provide any other remedial action.

Generic Letter 80-30 mandated all licensees revise the equivalent to LCO 3.0.3 to require

pressurized water reactors (PWRs) to be in Hot Standby within one hour and boiling water

reactors (BWRs) to be in Hot Shutdown within six hours. However, the 1980 versions of the

STS provided one hour to prepare before initiating a shutdown. The purpose of the one-hour

allowance was not discussed in the STS Bases, but Generic Letter (GL) 87-09, "Sections 3.0 and

4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions

for Operation and Surveillance Requirements," revised the Bases to state, "One hour is allowed

to prepare for an orderly shutdown before initiating a change in plant operation. This time

permits the operator to coordinate the reduction in electrical generation with the load dispatcher

to ensure the stability and availability of the electrical grid." All operating plants have adopted

the one-hour time to prepare in their equivalent of LCO 3.0.3.

In 1993, the NRC promulgated 10 CFR 50.65(a)(4) (i.e., the Maintenance Rule), which states,

"Before performing maintenance activities (including but not limited to surveillance, postmaintenance testing, and corrective and preventive maintenance), the licensee shall assess and

manage the increase in risk that may result from the proposed maintenance activities." The

industry has implemented this requirement using the guidance in Section 11 of NUMARC 93-01,

"Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

which is endorsed by NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants." The guidance is followed to reduce the likelihood of

initiating events, reduce the likelihood of the unavailability of redundant trains, and increase the

likelihood of successful operator actions in response to an initiating event. The risk assessment

and management activities required by 10 CFR 50.65(a)(4) are performed when TS equipment is

inoperable, such as the circumstances that can result in entry into LCO 3.0.3.

2.2. Current Technical Specifications Requirements

In the Pressurized Water Reactor (PWR) STS (NUREG-1430, NUREG-1431, NUREG-1432,

and NUREG-2194), LCO 3.0.3 states:

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met,

an associated ACTION is not provided, or if directed by the

associated ACTIONS, the unit shall be placed in a MODE or other

specified condition in which the LCO is not applicable. Action shall

be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ,

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TSTF-585, Rev. 3

Page 3

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual

Specifications.

Where corrective measures are completed that permit operation in

accordance with the LCO or ACTIONS, completion of the actions

required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

In the Boiling Water Reactor (BWR) STS (NUREG-1433 and NUREG-1434), the LCO 3.0.3

requirements reflect the differences between the PWR and BWR Mode definitions, but is

otherwise the same:

…place the unit, as applicable, in:

a. MODE 2 within [7]2 hours,

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

…

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

Some TS Actions direct entry into LCO 3.0.3. The following specifications explicitly require

entering LCO 3.0.3 in the stated Condition with a Completion Time of "Immediately" and are

proposed to be revised:

TS Number NUREG TS Title Condition

3.8.5 2194 Distribution Systems –

Operating

Two inoperable divisions that result

in a loss of safety function.

2

The NUREG-1433 TS include a Reviewer's Note that states that a longer time to reach MODE 2 may be justified

on a plant-specific basis.

DRAFT

TSTF-585, Rev. 3

Page 4

TS Number NUREG TS Title Condition

3.8.9 1430

1431

1432

1433

1434

Distribution Systems –

Operating

Two or more electrical power

distribution systems are inoperable

that result in a loss of function.

Some specifications may result in implicit entry into LCO 3.0.3 by not providing Actions for all

Conditions related to failure to meet the LCO. The following specifications may result in

implicit entry into LCO 3.0.3 and are proposed to be revised:

TS Number NUREG TS Title Condition

3.1.6 1430 AXIAL POWER SHAPING

ROD (APSR) Alignment

Limits

More than one APSR inoperable or

not aligned within its limits.

3.6.10 1431 Hydrogen Ignition System

(HIS) (Ice Condenser)

Two HIS trains inoperable.

More than one containment region

with no operable hydrogen igniter.

3.7.2 1430

1431

1432

Main Steam Isolation Valves

(MSIVs)

More than one MSIV inoperable in

Mode 1.

3.8.4 1430

1431

1432

1433

1434

DC Sources - Operating Two DC electrical power subsystems

inoperable.

2.3. Reason for the Proposed Change

The existing LCO 3.0.3 requires a rapid plant shutdown regardless of the risk significance of the

plant condition. The NRC has encouraged licensees to use risk assessment where practical to

reduce unnecessary conservatism associated with current regulatory requirements. The proposed

change requires a licensee to assess the risk significance of the degradation that led to entry into

LCO 3.0.3, to take the required risk management actions, and to shut down the plant in a time

frame based on the plant risk.

Historical information has shown that about half of the plant shutdowns initiated under

LCO 3.0.3 could be avoided if licensees had additional time to resolve the condition or obtain

relief from the NRC. While reactor operators are trained to perform a rapid plant shutdown,

moving from full power to cold shutdown is a major plant evolution that exercises an array of

plant equipment and procedures. Most TS-required equipment is in standby, and its inoperability

DRAFT

TSTF-585, Rev. 3

Page 5

does not threaten stable plant operation. Therefore, maneuvering the plant through a rapid

shutdown transient may be unwarranted for a limited period of time if plant risk is determined to

be acceptable and the required risk management actions are implemented.

2.4. Description of the Proposed Change

The proposed change revises LCO 3.0.3 to require a risk assessment to be performed and the

required risk management actions to be implemented within six hours of entry into LCO 3.0.3.

This requirement replaces the existing one-hour time to prepare for a plant shutdown in

LCO 3.0.3. If risk is assessed and managed and deemed to be acceptable, operation may

continue for a total of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after entry into LCO 3.0.3 (that is, eighteen hours after the period

permitted for the risk assessment.) At the end of that period, if the plant is still in LCO 3.0.3,

initiation of a shutdown is required. If the risk is determined to not be acceptable for continued

plant operation, a plant shutdown must be initiated. The proposed change to LCO 3.0.3 does not

alter the required times to enter lower Modes once a shutdown is initiated under LCO 3.0.3.

The following changes are proposed to LCO 3.0.3 (additions are in italics, deletions are struck

through):

PWR TS

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met,

an associated ACTION is not provided, or if directed by the

associated ACTIONS, the unit shall be placed in a MODE or other

specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable

systems and components and implement required risk

management actions. If the risk assessment determines that

continuing operation is acceptable, the required risk management

actions are implemented, and entry into LCO 3.0.3 was unplanned,

then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place

the unit, as applicable, in:

a. MODE 3 within 7 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ,

b. MODE 4 within 13 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and

c. MODE 5 within 37 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months .

If the risk assessment determines that continuing operation is not

acceptable, the risk assessment was not performed, the required

risk management actions were not implemented, or entry into LCO

3.0.3 was planned, then action shall be initiated to place the unit, as

applicable, in:

a. MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

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b. MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c. MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual

Specifications.

If Where corrective measures are completed that permit operation

in accordance with the LCO or ACTIONS, then completion of the

actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

BWR TS

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met,

an associated ACTION is not provided, or if directed by the

associated ACTIONS, the unit shall be placed in a MODE or other

specified condition in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable

systems and components and implement required risk

management actions. If the risk assessment determines that

continuing operation is acceptable, the required risk management

actions are implemented, and entry into LCO 3.0.3 was unplanned,

then action Action shall be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place

the unit, as applicable, in:

a. MODE 2 within [7 30] hours,

b. MODE 3 within 13 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and

c. MODE 4 within 37 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months .

If the risk assessment determines that continuing operation is not

acceptable, the risk assessment was not performed, the required

risk management actions were not implemented, or entry into LCO

3.0.3 was planned, then action shall be initiated to place the unit, as

applicable, in:

a. MODE 2 within [12] hours,

b. MODE 3 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

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TSTF-585, Rev. 3

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c. MODE 4 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual

Specifications.

If Where corrective measures are completed that permit operation

in accordance with the LCO or ACTIONS, then completion of the

actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

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

The brackets around the time provided to reach MODE 2 allow a

plant to extend the time from 6 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to a plant specific time.

Before the time can be changed, plant specific data must be

provided to support the extended time.

The Reviewer's Note and the brackets around the time to enter Mode 2 only appear in

NUREG-1433.

Other Proposed Changes

TS 3.8.9 in NUREG-1430 through NUREG-1434, and TS 3.8.5 in NUREG-2194, titled,

"Distribution Systems - Operating," is revised to replace a requirement to enter LCO 3.0.3

immediately with a requirement to shut down the plant.

 NUREG-1430, NUREG-1431, NUREG-1432

Condition E, "Two or more electrical power distribution subsystems inoperable that

result in a loss of safety function," Required Action E.1, "Enter LCO 3.0.3," is replaced

with Required Action E.1, "Be in MODE 3," with a Completion Time of six hours, and

Required Action E.2, "Be in MODE 5," with a Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

 NUREG-1433 and NUREG-1434

Condition F, "Two or more electrical power distribution subsystems inoperable that result

in a loss of safety function," Required Action F.1, "Enter LCO 3.0.3," is replaced with

Required Action F.1, "Be in MODE 3," with a Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and

Required Action F.2, "Be in MODE 4," with a Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

 NUREG-2194

Condition F, "Two inoperable divisions that result in a loss of safety function," is revised

to state, "Two or more inoperable divisions that result in a loss of safety function,"

Required Action F.1, "Enter LCO 3.0.3," is replaced with Required Action F.1, "Be in

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TSTF-585, Rev. 3

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MODE 3," with a Completion Time of six hours, and Required Action F.2, "Be in

MODE 5," with a Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

TS 3.1.6 in NUREG-1430, "AXIAL POWER SHAPING ROD (APSR) Alignment Limits," does

not contain a condition for more than one APSR inoperable or not aligned within its limits.

Existing Condition B, "Required Action and associated Completion Time not met," which

requires a plant shutdown, is revised to add a new Condition joined with a logical “OR” which

states, "Two or more APSRs inoperable, not aligned within its limits, or both."

TS 3.6.10 in NUREG-1431, "Hydrogen Ignition System (HIS) (Ice Condenser)," does not

contain a condition for both HIS trains inoperable or for more than one containment region with

no operable hydrogen ignitor. Existing Condition C, "Required Action and associated

Completion Time not met," which requires a plant shutdown, is revised to add two new

Conditions, each joined with a logical “OR” which state, "Both HIS trains inoperable," and

"More than one containment region with no OPERABLE hydrogen ignitor."

TS 3.7.2 in NUREG-1430, NUREG-1431, and NUREG-1432, "Main Steam Isolation Valves

(MSIVs)," does not contain a condition for more than one MSIV inoperable while in Mode 1.

Existing Condition C provides Required Actions for one or more MSIVs inoperable in Mode 2

or 3. Existing Condition B, "Required Action and associated Completion Time of Condition A

not met," which requires being in Mode 2 within six hours, is revised to add a new Condition

joined with a logical “OR” which states, "More than one MSIV inoperable in MODE 1."

TS 3.8.4 in NUREG-1430 through NUREG-1434, "Distribution Systems - Operating," does not

contain a condition for more than one DC subsystem inoperable (called "station service DC

subsystems" in NUREG-1433 and "Division 1 and 2" DC subsystems in NUREG-1434.). A new

Condition E is added for the condition of both DC electrical power subsystems inoperable. New

Required Action E.1 directs being in Mode 3 in six hours in NUREG-1430 through

NUREG-1432 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in NUREG-1433 and NUREG-1434. New Required Action E.2

directs being in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in NUREG-1430 through NUREG 1432 and to be in Mode 4

in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in NUREG-1433 and NUREG-1434.

The TS Bases are revised to reflect these changes.

The NUREG-2194 LCO 3.0.3 Bases are also revised to incorporate changes approved by the

NRC in TSTF-529, "Clarify Use and Application Rules," in order to make the TS Bases

consistent with the other STS NUREGs.

Title 10 of the Code of Federal Regulations (10 CFR), Part 50.36, states, "A summary statement

of the bases or reasons for such specifications, other than those covering administrative controls,

shall also be included in the application, but shall not become part of the technical

specifications." A licensee may make changes to the TS Bases without prior NRC review and

approval in accordance with the Technical Specifications Bases Control Program. The proposed

TS Bases changes are consistent with the proposed TS changes and provide the purpose for each

requirement in the specification consistent with the Commission's Final Policy Statement on

Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993

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(58 FR 39132). Therefore, the Bases changes are provided for information, and approval of the

Bases is not requested.

A model application is attached. The model may be used by licensees desiring to adopt the

traveler following NRC approval.

3. TECHNICAL EVALUATION

The proposed change revises the TS to require a risk assessment to be performed, and the

required risk management actions to be implemented, within six hours of entering LCO 3.0.3.

This requirement replaces the current one-hour period provided to prepare for a shutdown. The

plant conditions that may result in entering LCO 3.0.3 have differing levels of risk significance.

Unlike the current “one size fits all” approach in the current LCO 3.0.3, the proposed change

requires risk to be assessed and risk management actions to be implemented, and the timing of

the subsequent plant shutdown is informed by the risk assessment. If the risk-assessment

determines that continued plant operation is acceptable and the entry into LCO 3.0.3 was not

planned, initiation of a plant shutdown is required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3. This 24-

hour period is provided to prepare for the shutdown, make repairs, or obtain relief from the NRC.

If the risk assessment determines that continued plant operation is not acceptable (or if the risk

assessment or credited risk management actions are not completed, or the LCO 3.0.3 entry was

planned), initiation of a plant shutdown is required immediately following the risk assessment.

The proposed change does not alter the times permitted to enter lower Modes once a shutdown is

initiated.

The proposed change also revises several specifications to require a plant shutdown instead of

explicitly or implicitly requiring entry into LCO 3.0.3. This has no practical effect on plant

operation or safety except that the existing hour to prepare for a shutdown in LCO 3.0.3 is not

incorporated into the revised TS Actions. This change is more restrictive, but maintaining the

allowance of one hour was deemed to be less valuable than maintaining consistency within the

TS given the small likelihood that the Actions would be entered.

3.1. LCO 3.0.3 Change Overview

3.1.1. The Proposed Change is Consistent with the Regulations

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.36(c)(2), "Limiting

Conditions for Operation," states, "When a limiting condition for operation of a nuclear reactor is

not met, the licensee shall shut down the reactor or follow any remedial action permitted by the

technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by

providing a requirement to shut down the reactor if an LCO is not met and the TS does not

provide any other remedial action. 10 CFR 50.36(c)(2) does not specify a timeframe for a

licensee to shut down the reactor if an LCO is not met. The NRC has found it consistent with

10 CFR 50.36 for the current plant TS to contain a one-hour delay before initiating a plant

shutdown. Since the length of the delay is not specified in the regulations, the proposed 6-hour

period to assess risk, and the potential for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before initiating a plant shutdown is also

consistent with 10 CFR 50.36(c)(2).

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The proposed changes to incorporate Actions to initiate a shutdown instead of explicit or implicit

entry into LCO 3.0.3 does not change the requirement to shut down the plant. Therefore, these

changes are also consistent with 10 CFR 50.36(c)(2).

3.1.2. The Proposed Change Improves Plant Safety

Nuclear plant operators are trained to perform a rapid plant shutdown and practice such

shutdowns in plant simulators but are rarely called on to do so in the plant. Most TS-required

plant shutdowns are preceded by an Action that provides time to restore compliance and

TS-required immediate plant shutdowns are rare. A review of ten years of Licensee Event

Reports (LERs) (2010 - 2020) identified 52 immediate plant shutdowns that were required by the

TS over approximately 1000 reactor-years of operation (i.e., approximately one per 20

reactor-years). As a result, immediate plant shutdowns are considered to be infrequent

evolutions. Licensees typically implement additional administrative requirements to minimize

the risk from infrequent evolutions, but the abbreviated time to initiate a shutdown provided by

LCO 3.0.3 may not provide time to implement those precautions.

A plant shutdown under LCO 3.0.3 is also time-critical in that a major plant evolution must be

initiated within one hour. A TS-required immediate plant shutdown includes many activities,

such as stopping maintenance or testing and restoring systems, or planning for a shutdown with

unavailable systems. Human performance studies indicate that time-critical actions are more

error prone and providing additional time to initiate a plant shutdown under LCO 3.0.3 could

relieve time pressure and reduce the risk of human error.

The NRC's Notice of Enforcement Discretion guidance (NRC Enforcement Manual, Appendix F,

"Notices of Enforcement Discretion,") recognizes that a plant shutdown is not always the safest

course of action:

The NRC has historically recognized that the two safest modes for operating a nuclear

power plant are either Mode 5 (shut down) or Mode 1 (operating at power). Transitions

between these two modes may introduce situations or configurations that involve an

increase in risk. The NRC expects its licensees to comply with all applicable

requirements (i.e., regulations, license conditions, etc.). However, circumstances may

arise at an operating NPP where compliance with a TS LCO or a license condition would

result in an unnecessary transient without a corresponding health and safety benefit; or a

situation may exist where potential radiological or other hazards of continued operation

must be balanced against public health and safety or common defense and security.

A comparison of Emergency Notification System (ENS) data to LER data was performed

examining the ten-year period of 2010 – 2020. An ENS notification is required when a plant

shutdown required by the TS is initiated. An LER is required when a plant shutdown required by

the TS is completed. The review determined that only about half of the plant shutdowns initiated

under LCO 3.0.3 resulted in a shutdown. This indicates that if licensees had additional time to

resolve the condition, the plant transient associated with initiating a plant shutdown could have

been avoided.

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The goal of the proposed change is to improve plant safety by requiring an assessment of the risk

of continued plant operation to determine whether an immediate shutdown is appropriate or if

providing additional time that may avoid an unwarranted plant transient is justified.

The proposed change also revises certain TS Actions to require a plant shutdown instead of

invoking LCO 3.0.3. These revised Actions are applicable in conditions which would not

warrant additional time or for which risk cannot be assessed.

3.1.3. The Proposed Change Leverages Existing Risk Management Tools

3.1.3.1. 10 CFR 50.65(a)(4)

The proposed change requires that risk be assessed and managed when LCO 3.0.3 is entered.

The requirement to assess and manage risk has previously been added to:

 LCO 3.0.4 (Mode changes),

 LCO 3.0.8 (Nonfunctional Snubbers),

 LCO 3.0.9 (Nonfunctional Barriers), and

 SR 3.0.3 (Missed Surveillances).

In all of these cases, risk is assessed using the existing 10 CFR 50.65(a)(4) (i.e., the Maintenance

Rule) tools, which have been in use for over 20 years and are readily available to operators. The

NRC's approval of these changes and the TS Bases require the risk assessments to be conducted

using the procedures and guidance in Section 11 of NUMARC 93-01, "Industry Guideline for

Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which is endorsed by

NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants." These tools are used to reduce the likelihood of initiating events, reduce the likelihood of

the unavailability of redundant trains, and increase the likelihood of successful operator actions

in response to an initiating event. The risk assessment must consider all inoperable TS

equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4)

risk assessment scope. The same requirements are imposed by the proposed change.

Section 11 of NUMARC 93-01 provides guidance for conduct of the risk assessment,

quantitative and qualitative guidelines for establishing risk management actions, and example

risk management actions. Assessing the risk means using a risk-informed process to evaluate the

overall contribution to risk as a result of inoperable equipment. Managing the risk also means

providing plant personnel with proper awareness of the risk and taking actions as appropriate to

control the risk. The process for conducting the risk assessments and using the result of the

assessment in plant decisionmaking is proceduralized and denotes responsibilities and processes

for conducting the assessment for cases when the plant configuration is not covered by the

normal assessment tool.

In the operating Modes in which LCO 3.0.3 is applicable, the risk assessment considers the

impact on the key plant safety functions that ensure the integrity of the reactor coolant pressure

boundary, ensure the capability to shut down and maintain the reactor in a safe shutdown

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condition, and ensure the capability to prevent or mitigate the consequences of accidents that

could result in potentially significant offsite exposures.

The risk assessment considers factors such as:

 Technical specifications requirements;

 The degree of redundancy available for performance of the safety function(s) served by

the inoperable equipment;

 The duration of the condition;

 The likelihood of an initiating event or accident that would require the performance of the

affected safety function;

 The likelihood that the inoperable equipment will significantly increase the frequency of

a risk-significant initiating event;

 Component and system dependencies that are affected; and

 Significant performance issues for the in-service redundant SSCs.

NUMARC 93-01, Section 11.3.2, "General Guidance for the Assessment - Power Operations and

Shutdown," also addresses the evaluation of emergent conditions, such as those leading to entry

into LCO 3.0.3. The risk assessment must consider emergent conditions, such as inoperable

equipment due to failures, or significant changes in external conditions (weather, offsite power

availability). The risk assessment must also consider internal events, internal floods, and internal

fires.

Risk management actions include planning and conducting plant activities in a manner that

controls overall risk, increased risk awareness by shift and management personnel, and actions to

minimize the magnitude of risk increases (establishment of backup success paths or

compensatory measures).

Risk assessment and risk management actions consider the activities required to restore the

inoperable equipment, such as jumpering terminals, lifting leads, placing temporary lead

shielding on pipes and equipment, removal of barriers, and use of temporary blocks, bypasses,

scaffolding and supports.

NEI 18-10

Some licensees use NEI 18-10, "Monitoring the Effectiveness of Nuclear Power Plant

Maintenance," as guidance in implementing 10 CFR 50.65 (i.e., the Maintenance Rule) in lieu of

NUMARC 93-01. The primary difference between NEI 18-10 and NUMARC 93-01 is in the

implementation of 10 CFR 50.65(a)(2), which governs which systems are subject to preventative

maintenance programs. However, the risk assessment performed to support the existing and

proposed TS includes all inoperable TS equipment regardless of whether the equipment is

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included in the normal 10 CFR 50.65(a)(4) risk assessment scope. Therefore, the use of NEI 18-

10 has no effect on the applicability of the proposed change.

NEI 18-10, Section 11, "(A)(4) Assessment," was copied from Section 11 of NUMARC 93-01

without change. Therefore, it is accurate to state that the risk assessments will be conducted

using the procedures and guidance endorsed by Regulatory Guide 1.160, which endorses the

guidance in Section 11 of NUMARC 93-01, regardless of whether the licensee is following

NUMARC 93-01 or NEI 18-10.

FLEX and Other Mitigating Strategies

In response to the accident at Fukushima Dai-ichi, the NRC issued Order EA-12-049, “Order

Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-DesignBasis External Events.” The Order required licensees to implement diverse and flexible

mitigation strategies, known as FLEX, that will increase defense-in-depth for beyond-designbasis scenarios.

As described in NEI 12-06, “Diverse and Flexible Coping Strategies (FLEX) Implementation

Guide,” FLEX consists of:

 Both plant and FLEX equipment that provides means of obtaining power and water to

maintain or restore key safety functions for all reactors at a site;

 Reasonable staging and protection of FLEX equipment from beyond-design-basis

external events applicable to a site;

 Procedures and guidance to implement FLEX strategies; and

 Programmatic controls that assure the continued viability and reliability of the FLEX

strategies.

Note that the FLEX strategies are focused on maintaining or restoring key plant safety functions

and are not tied to any specific damage state or mechanistic assessment of external events.

NEI 16-06, “Crediting Mitigating Strategies in Risk-Informed Decision Making,” provides

guidance on the use of plant mitigating strategies in risk-informed decision making, such as

Maintenance Rule risk assessments and mitigating actions. These mitigating strategies employ

plant responses that utilize portable equipment to restore or maintain various safety functions

during beyond design basis conditions and the loss of permanently installed plant equipment.

Examples of these strategies include FLEX and may also include other mitigating strategies as

discussed in NRC Regulatory Issue Summary (RIS) 2008-15, “NRC Staff Position on Crediting

Mitigating Strategies Implemented in Response to Security Orders in Risk-Informed Licensing

Actions and in the Significance Determination Process.”

As part of their 10 CFR 50.65(a)(4) risk assessment process, licensees may consider FLEX and

other mitigating strategies when choosing risk management actions and assessing the risk

associated with continued plant operation while in LCO 3.0.3.

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3.2. LCO 3.0.3 Detailed Justification

3.2.1. Time to Assess and Manage Risk and Implement Risk Management Actions

The proposed change adds a new requirement to LCO 3.0.3 to perform a risk assessment and

implement the required risk management actions. This new requirement is applicable regardless

of any intent to defer a plant shutdown if the risk assessment determines that continuing

operation is acceptable. The proposed change provides six hours to perform the risk assessment

and implement the required risk management actions and replaces the current one-hour

allowance in LCO 3.0.3 to prepare for a plant shutdown. The six-hour period is considered

appropriate because:

 All licensees have computer software that can calculate plant risk based on the plant

configuration used to implement 10 CFR 50.65(a)(4). The time to calculate the risk will

vary depending on the software, hardware, and the complexity of the plant condition. It

may be necessary to engage the licensees Probabilistic Risk Assessment (PRA) staff in

order to determine the quantitative or qualitative risk. These activities may take from one

to several hours.

 The time required to implement risk management actions, such as briefing the operating

staff, protecting equipment, or pre-staging FLEX equipment, varies and may require

additional staff.

Taken together, a six-hour period to perform the risk assessment and implement the risk

management actions is reasonable.

In addition, licensed operators are trained to take conservative actions to protect the plant.

Should plant conditions warrant immediate action to ensure safety or if continued safe operation

of the plant is uncertain, licensed operators will take appropriate action regardless of allowances

in the TS.

3.2.2. Plant Operation May Continue if Risk is Acceptable

If the risk assessment determines that continuing operation is acceptable and entry into

LCO 3.0.3 was unplanned, and the required risk management actions have been implemented,

licensees are required to initiate action within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3 to place the unit

in a Mode or other specified condition in which the initiating LCO is not applicable. The term

“continuing operation is acceptable,” means that the condition represents no more than a minimal

increase in risk after implementation of any risk management actions (i.e., the level determined

acceptable during normal work control levels3

). The term “required risk management actions”

means those risk management actions that are quantitatively or qualitatively credited in the risk

3

NUMARC 93-01 describes an activity subject to "normal work controls" as having an incremental core damage

probability (ICDP) < 1E-6 and an Incremental Large Early Release Probability (ILERP) of < 1E-7.

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assessment and are necessary for the risk assessment to demonstrate that continued plant

operation is acceptable.

Assessment and management of risk requires knowing the likely cause of the failures or

variables outside of their limits that resulted in LCO 3.0.3 entry in order to assess the risk and to

take the appropriate risk management actions. A formal cause or apparent cause evaluation is

not required because of the limited time available; however, the likely cause should be known. If

the extent of condition is unknown, the risk assessment should consider the increased possibility

of common cause failure either numerically or through risk management actions.

3.2.3. Plant Operation May Continue if the LCO 3.0.3 Entry is Unplanned

The requirement to initiate actions to shut down the plant within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into

LCO 3.0.3 may not be used if the entry into LCO 3.0.3 is planned. For example, if Train A of a

two-train system is inoperable due to maintenance, the licensee may not plan to make Train B

inoperable such that LCO 3.0.3 is applicable and then apply LCO 3.0.3 to defer initiation of a

shutdown. However, if Train A of a two-train system is inoperable for maintenance and

emergent conditions result in Train B being inoperable causing entry into LCO 3.0.3 and the risk

assessment and risk management requirements are satisfied, the 24-hour allowance may be used.

As stated in the current TS Bases, planned entry into LCO 3.0.3 should be avoided. If it is not

practicable to avoid planned entry into LCO 3.0.3, plant risk should be assessed and managed in

accordance with 10 CFR 50.65(a)(4), and the planned entry into LCO 3.0.3 should have less

effect on plant safety than other practicable alternatives. While these actions are similar to those

required by the proposed LCO 3.0.3, planned use of the extended period of operation permitted

under the proposed LCO 3.0.3 would be inconsistent with the safety basis for the existing TS

Completion Times, which considered the need for planned entries.

3.2.4. Basis for the 24-Hour Period

On entry into LCO 3.0.3, a licensee will typically be pursuing four activities in parallel:

 Performance of a risk assessment and implementation of risk management actions;

 Preparing for an orderly plant shutdown;

 Working to restore equipment to operable status or parameters to within limits in order to

exit LCO 3.0.3; or

 Evaluating whether to request relief from the NRC.

If within the first six hours the risk assessment determines that continuing operation is

acceptable, risk management actions have been implemented, and the entry into LCO 3.0.3 was

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unplanned, licensees may pursue the remaining actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into LCO 3.0.3.

The 24-hour period is based on pursuing these goals.

Preparing for an orderly plant shutdown may include many activities, such as:

 Bring an additional operating crew on site to support the shutdown, which considers that

the LCO 3.0.3 entry may occur on a weekend, holiday, or during a night shift when there

may be less staff on site.

 Bring in additional site technical and maintenance support staff to secure any station

maintenance in progress, restore any inoperable components necessary for shutdown, or

address any maintenance issues that arise during shutdown.

 Bring in simulator staff to support simulator exercises of a shutdown with the inoperable

equipment that led to entry into LCO 3.0.3. The simulator staff must familiarize

themselves with the situation and prepare training scenarios.

 Conduct simulator training to prepare the crew for the shutdown considering the current

plant condition, including the inoperable equipment. This may include turn over to

another shift crew to staff the control room during training.

 Perform just-in-time procedure reviews to prepare for the shutdown. Additional

operating staff may be needed to allow the shutdown shift to perform the reviews.

 Coordinate with the transmission load dispatcher for power requirements with the station

offline.

Therefore, if the proposed conditions are met, providing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 to

prepare for a shutdown is reasonable.

The licensee should have a reasonable scope and schedule for restoring compliance such that

LCO 3.0.3 is no longer applicable. However, it is not required that the schedule be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or

less, as the licensee may be pursuing regulatory relief or an orderly shutdown in addition to

working to restore compliance with the LCOs.

In parallel with repairs and preparing for an orderly shutdown, the licensee may request

regulatory relief to provide additional time to repair the condition. The NRC Enforcement

Manual, Appendix F, "Notices of Enforcement Discretion," describes the process for considering

enforcement discretion. While not impossible, it is unlikely that a licensee could provide the

requested information and for the NRC staff to have sufficient time to consider the request and

render a decision under the current LCO 3.0.3 one-hour period before a plant shutdown is

initiated. However, if the proposed conditions are satisfied, the proposed 24-hour period would

be sufficient for the licensee to request and for the NRC to consider enforcement discretion or an

emergency license amendment under the provisions of 10 CFR 50.91(a)(5). Until such relief is

granted, the licensee must follow their TS.

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3.3. LCO 3.0.3 Editorial Changes

The revision to LCO 3.0.3 required a change to the time to be in the listed Modes. One hour is

subtracted from each time because the existing one-hour delay time is removed and six or

twenty-four hours are added to the times to reflect the time provided to perform the risk

assessment and, if justified, the additional time for continued plant operation. All times are

based on the entry into LCO 3.0.3.

The penultimate paragraph of LCO 3.0.3 states, "Where corrective measures are completed that

permit operation in accordance with the LCO or ACTIONS, completion of the actions required

by LCO 3.0.3 is not required." This is revised to state, "If corrective measures are completed…,

then …" as an editorial improvement.

3.4. Other TS Changes

3.4.1. Other TS Evaluation

The industry evaluated the STS NUREGs and identified the Actions that invoked LCO 3.0.3

explicitly and also identified specifications that lacked Actions for obvious failures to meet the

LCO, such as not providing an Action for two inoperable trains in specifications that require two

trains to be operable. Each Action or specification was then examined, considering factors such

as:

 Could the Condition affect safe plant operation assuming no other failures or accidents?

 Could the Condition be assessed for its risk impact?

 Could the Condition be entered for failures that would not significantly degrade the

ability of the system to perform its primary function?

 Are there proceduralized actions that can be taken to diminish the impact of the failure?

 Would an immediate plant shutdown be complicated by the failure?

It was determined that no changes are needed for most specifications and the proposed revision

to LCO 3.0.3 would be appropriate if the conditions for use are met. For example:

 The "Emergency Core Cooling System - Operating" specification Actions for PWRs

requires entering LCO 3.0.3 when less than 100% of the ECCS flow equivalent to a

single operable train is available. For BWRs, LCO 3.0.3 entry is required for several

combinations of inoperable equipment that would prevent the ECCS from performing its

required function. However, the proposed LCO 3.0.3 is appropriate for this condition.

At most PWR and BWR plants, the low pressure ECCS components are also used for

decay heat removal during shutdown. Requiring an immediate plant shutdown to a

condition that could require the use of an inoperable decay heat removal system may be

unwarranted. Also, high pressure injection is typically a low-risk system (risk informed

Completion Times typically greater than 30 days) and time to diagnose and potentially

correct inoperabilities should be permitted.

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 The PWR Control Room Emergency Filtration System (CREFS) requires entering

LCO 3.0.3 if two CREFS trains are inoperable for reasons other than an inoperable

boundary. However, if both CREFS trains are inoperable due to an inoperable boundary,

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are provided to determine if the control room occupants can be protected (and, if

so, 90 days are provided to restore the boundary.) Using the proposed LCO 3.0.3 if the

conditions are met is appropriate for this condition as 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are already provided when

the safety function cannot be performed.

 The "AC Sources - Operating" specification requires entering LCO 3.0.3 when three or

more required AC sources are inoperable. Using the proposed LCO 3.0.3 if the

conditions are met is appropriate for this condition. If both offsite circuits are inoperable,

a plant trip will likely render LCO 3.0.3 entry moot. However, if the unit continues to

operate in this TS condition (for example, if two DGs and one offsite circuit are

inoperable), requiring an immediate plant shutdown and removal of the main generator as

a power source should be avoided. If plant risk is assessed and managed, permitting

additional time to restore sufficient capability to exit LCO 3.0.3 before initiating a

shutdown is reasonable. Note that the proposed change does not alter the existing TS

Actions that require restoring at least one of two inoperable DGs within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . If an

offsite circuit and DG are both inoperable, the TS requires one to be restored within 12

hours. As discussed in TS Example 1.3-2, these Actions continue and effectively limit

the application of the proposed change to LCO 3.0.3.

 Many TS instrumentation functions do not include a Condition for all required channels

for a function being inoperable. Using the proposed LCO 3.0.3 if the conditions are met

is appropriate for these conditions. Disturbing the plant when instrumentation is

inoperable could result in a reactor trip or inadvertent actuation. Moreover, there are

usually redundant and diverse ways of determining important plant parameters and most

initiation functions have multiple methods of achieving the goal. Most automatic

functions can be manually performed by an operator using existing procedures.

However, if the plant is in an unknown state, plant operators are trained to take

conservative action to protect plant safety, such as manually initiating a reactor trip.

Lastly, if a channel is out of service for testing or maintenance, it usually can be restored,

and the condition exited.

The evaluation identified some specifications that should be revised to eliminate an explicit or

implicit entry into LCO 3.0.3 and to instead require a plant shutdown or other appropriate

actions.

3.4.2. Other TS Changes

3.4.2.1. NUREG-1430, TS 3.1.6, "AXIAL POWER SHAPING ROD (APSR) Alignment

Limits"

The specification requires each APSR to be operable and aligned with its group average height.

There is no TS Action for more than one inoperable APSR or more than one APSR not aligned

with the group average height. More than one misaligned APSR may produce unacceptable

power peaking factors and linear heat generation rates. A risk assessment cannot be performed

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for reactor parameters. Therefore, the implicit LCO 3.0.3 entry is replaced with a requirement to

shut down the reactor by modifying the existing default Action to be in Mode 3 within six hours

with an additional Condition applicable when two or more APSRs are inoperable or not aligned

within the limits.

3.4.2.2. NUREG-1431, TS 3.6.10, "Hydrogen Ignition System (HIS)"

The specification is applicable to plants with an ice condenser containment design. Two HIS

trains are required to be operable. There are no Conditions for both HIS trains inoperable or for

more than one containment region with no operable hydrogen ignitor. Ice condenser plants are

vulnerable to hydrogen ignition in post-accident environments because of their small

containment volume. The unavailability of both HIS trains or of the ignitors in more than one

compartment could lead to hydrogen buildup and ignition, potentially overpressurizing the

containment or damaging equipment. Therefore, the implicit LCO 3.0.3 entry is replaced with a

requirement to shut down the reactor by modifying the existing default Action to be in Mode 3

within six hours with an additional Condition applicable when both HIS trains are inoperable, or

if there is more than one containment region with no operable hydrogen ignitor.

3.4.2.3. NUREG-1430, NUREG-1431, and NUREG-1432, TS 3.7.2, "Main Steam Isolation

Valves (MSIVs)"

The specifications require the MSIV on each steam line to be operable in Mode 1, and in Modes

2 and 3 except when all MSIVs are closed. There is an Action for one MSIV inoperable in

Mode 1 and an Action for one or more MSIVs inoperable in Mode 2 or 3, but there is no Action

for more than one MSIV inoperable in Mode 1. The MSIVs are the primary mitigation

mechanism for a number of events, such as a steam generator tube rupture, a high-energy line

break inside containment, a main steam line break outside of the containment, and a feedwater

line break. Inoperability of more than one MSIV, particularly in plants with only two or three

main steam lines, would have a significant impact on the plant's ability to respond to these

events. Therefore, the implicit LCO 3.0.3 entry is replaced with a requirement to exit Mode 1 by

modifying the existing default Action to be in Mode 2 within six hours with an additional

Condition applicable when more than one MSIV is inoperable while in Mode 1.

3.4.2.4. NUREG-1430 through NUREG-1434 TS 3.8.4, "DC Sources - Operating"

The specifications require two subsystems or divisions of DC power to be operable. The

specification contains an Action for the battery or batteries and battery charger(s) on one

subsystem or division inoperable but does not contain an Action for more than one DC electrical

power subsystem inoperable. The batteries, along with the inverters, are the uninterruptible

power source for the reactor protection and engineered safety feature instrumentation and

controls. As most at-power accident analyses assume a loss of normal power and credit the

reactor protection and engineered safety feature instrumentation and controls, loss of more than

one DC electrical subsystem would have a significant impact on the plant's ability to respond to

an accident. Therefore, the implicit LCO 3.0.3 entry is replaced with a new Action with

Required Actions to shut down the reactor and exit the Applicability of the specification in the

timeframes used in the examples in Section 1.3 of the STS.

DRAFT

TSTF-585, Rev. 3

Page 20

3.4.2.5. NUREG-1430 through NUREG-1434 TS 3.8.9, and NUREG-2194 TS 3.8.5,

"Distribution Systems - Operating"

The specifications require entry into LCO 3.0.3 when two or more inoperable divisions or

subsystems result in a loss of function. Electrical distribution includes AC, DC, and AC Vital

Bus systems. When two or more electrical power distribution subsystems are inoperable that

result in a loss of safety function, the remaining subsystems are no longer capable of supporting

the minimum safety functions necessary to shut down the reactor and maintain it in a safe

shutdown condition without assuming any additional failures. Therefore, an immediate plant

shutdown is warranted. The Required Action to enter LCO 3.0.3 is replaced with Required

Actions to shut down the reactor and exit the Applicability of the specification in the timeframes

used in the examples in Section 1.3 of the STS. The Required Actions and Completion Times

are consistent with the other Actions in the TS and the Examples in TS Section 1.3.

3.5. TS Bases Changes

The TS Bases are revised to reflect the proposed TS changes. The LCO 3.0.3 Bases discuss the

requirement that risk be assessed and managed, and state that the risk assessment must be

conducted using the procedures and guidance endorsed by Regulatory Guide 1.160 and

Section 11 of NUMARC 93-01, and that the risk assessment must determine that continuing

operation is acceptable. Acceptability is based on the guidelines in NUMARC 93-01; that is,

there should be no more than minimal increase in risk after implementation of risk management

actions (i.e., the level determined acceptable during normal work control levels). The model

application requires the licensee to confirm that this guidance will be followed. The Bases also

discuss the treatment of common cause in the risk assessment and which risk management

actions are considered to be required.

Editorial changes are made to the LCO 3.0.3 Bases to improve consistency and clarity.

 LCO 3.0.3 describes three conditions on entry, but the TS Bases combine two of those

reasons. The Bases are revised to be consistent with the TS.

 The LCO 3.0.3 Bases state, “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.” While the

phrase, “within the limits for safe operation,” may be correct, it is not one of the

conditions given for entering LCO 3.0.3 in the TS and perpetuates a common

misunderstanding that LCO 3.0.3 entry may be required for reasons other than those

stated in the TS. Therefore, the phrase “for safe operation” is removed.

The NUREG-2194 LCO 3.0.3 Bases are also revised to incorporate changes approved by the

NRC in TSTF-529, "Clarify Use and Application Rules," in order to make the TS Bases

consistent between the STS NUREGs. The NRC approved TSTF-529, Revision 4, on April 21,

2016, for NUREG-1430 through NUREG-1434 (see NRC Agencywide Documents Access and

Management System (ADAMS) Accession No. ML16060A441.) The changes to the

NUREG-2194 LCO 3.0.3 Bases are:

DRAFT

TSTF-585, Rev. 3

Page 21

 The LCO 3.0.3 Bases uses the term "reaching" when describing a transition to a lower

Mode. The term "entering" is more accurate and is the commonly used term in the TS for

Mode transitions. In seven locations in the LCO 3.0.3 Bases, the term "reaching" a Mode

is replaced with the term "entering" a Mode. These changes do not represent any change

in intent but are made for consistency within the STS.

 The LCO 3.0.3 Bases list the conditions under which a unit shutdown required in

accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited. This list is

incomplete because it does not acknowledge that a unit shutdown may be terminated and

LCO 3.0.3 exited if the LCO is no longer applicable (i.e., the LCO that was not met

which led to entry into LCO 3.0.3). The proposed change adds to the list a new

paragraph b that states, "The LCO is no longer applicable," and the subsequent list items

are renumbered. This change does not represent any change in intent but is made for

consistency within the STS.

3.6. Conclusion

The proposed change will enhance plant safety by assessing and managing plant risk when

LCO 3.0.3 is entered, and avoiding unnecessary plant shutdown transients if the risk is

acceptable. This permits time to rectify the condition, prepare for an orderly plant shutdown, or

request NRC relief.

4. REGULATORY EVALUATION

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b)

requires:

Each license authorizing operation of a … utilization facility … will include technical

specifications. The technical specifications will be derived from the analyses and

evaluation included in the safety analysis report, and amendments thereto, submitted

pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The

Commission may include such additional technical specifications as the Commission

finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an

amendment must be filed with the Commission, fully describing the changes desired, and

following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the

applicant, the Commission will be guided by the considerations that govern the issuance of initial

licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical

Specifications Improvements for Nuclear Power Reactors" (58 FR 39132), dated July 22, 1993,

states in part that improved STS have been developed and will be maintained for each NSSS

owners group. The Commission Policy encourages licensees to use the improved STS as the

basis for plant-specific Technical Specifications." The industry's proposal of travelers and the

NRC's approval of travelers is the method used to maintain the improved STS as described in the

DRAFT

TSTF-585, Rev. 3

Page 22

Commission's Policy. Following NRC approval, licensees adopt travelers into their plantspecific technical specifications following the requirements of 10 CFR 50.90. Therefore, the

traveler process facilitates the Commission's policy while satisfying the requirements of the

applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary

statement of the bases or reasons for such specifications, other than those covering administrative

controls".

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that

the health and safety of the public will not be endangered by operation in the proposed manner,

(2) such activities will be conducted in compliance with the Commission’s regulations, and (3)

the approval of the proposed change will not be inimical to the common defense and security or

to the health and safety of the public.

5. REFERENCES

None

DRAFT

TSTF-585, Rev. 3

Model Application

DRAFT

TSTF-585, Rev. 3

Page 1

[DATE] 10 CFR 50.90

ATTN: Document Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

DOCKET NO. PLANT NAME

[50][52]-[xxx]

SUBJECT: Application to Revise Technical Specifications to Adopt

TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk"

Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the

Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT

NAME, UNIT NOS] TS. TSTF-585 revises Limiting Condition for Operation (LCO) 3.0.3 to

require assessing and managing plant risk whenever LCO 3.0.3 is entered. If the risk assessment

determines that continued plant operation is acceptable and other conditions are satisfied, 24

hours from entry into LCO 3.0.3 is permitted to initiate a shutdown. Otherwise, initiation of the

shutdown is required immediately. The proposed amendment also revises or adds some TS

Required Actions to direct a plant shutdown instead of entry into LCO 3.0.3.

The enclosure provides a description and assessment of the proposed changes. Attachment 1

provides the existing TS pages marked to show the proposed changes. Attachment 2 provides

revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show

revised text associated with the proposed TS changes and is provided for information only.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line-Item

Improvement Process (CLIIP). Approval of the proposed amendment is requested within six

months of completion of the NRC’s acceptance review. Once approved, the amendment shall be

implemented within 90 days.

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided

to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed

original under oath or affirmation. This can be accomplished by attaching a notarized affidavit

confirming the signature authority of the signatory, or by including the following statement in

the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require

notarization.]

DRAFT

TSTF-585, Rev. 3

Page 2

If you should have any questions regarding this submittal, please contact [NAME, TITLE,

TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure: Description and Assessment

Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases Changes (Mark-Up) – For

Information Only

[The attachments are to be provided by the licensee and are not included in the model

application.]

cc: NRC Project Manager

NRC Regional Office

NRC Resident Inspector

State Contact

DRAFT

TSTF-585, Rev. 3

Page 3

ENCLOSURE

DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-585, "Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT

NAME, UNIT NOS] Technical Specifications (TS). TSTF-585 revises Limiting Condition for

Operation (LCO) 3.0.3 to require a risk assessment to be performed and risk management actions

to be implemented within six hours. If the risk assessment determines that continued plant

operation is acceptable and other conditions are satisfied, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is

permitted to initiate a shutdown. Otherwise, initiation of the shutdown is required immediately.

The proposed amendment also revises or adds some TS Required Actions to direct a plant

shutdown instead of entry into LCO 3.0.3.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-585 provided to the Technical

Specifications Task Force in a letter dated [DATE]. This review included a review of the NRC

staff’s evaluation, as well as the information provided in TSTF-585. [As described herein,]

[LICENSEE] has concluded that the justifications presented in TSTF-585 and the safety

evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this

amendment for the incorporation of the changes to the [PLANT] TS.

[LICENSEE] confirms Section 11 of NUMARC 93-01, including the action thresholds under

normal work controls, will be used to perform the LCO 3.0.3 risk assessment to determine

whether continued plant operation is acceptable.

[LICENSEE] has reviewed the [PLANT] plant-specific specifications that do not appear in the

STS. [LICENSEE] has determined that [none of the] [the following] plant-specific

specifications should be revised to require a plant shutdown instead of entering LCO 3.0.3.]

[Describe any additional changes.]

2.2 Variations

[[LICENSEE] is not proposing any variations from the TS changes described in TSTF-585 or the

applicable parts of the NRC staff’s safety evaluation dated [DATE.]] [[LICENSEE] is proposing

the following variations from the TS changes described in TSTF-585 or the applicable parts of

the NRC staff’s safety evaluation: [Describe the variations.]]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-585

was based. Specifically, [describe differences between the plant-specific TS numbering and/or

titles and the TSTF-585 numbering and titles.] These differences are administrative and do not

affect the applicability of TSTF-585 to the [PLANT] TS.]

DRAFT

TSTF-585, Rev. 3

Page 4

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-585 was based

but are encompassed in the TSTF-585 justification. [Describe differences and why TSTF-585 is

still applicable.]]

[The [PLANT] TS contain Actions for conditions that are added or modified in the traveler to

avoid entry into LCO 3.0.3. They are [describe.] As a result, these traveler changes are not

applicable. This does not affect the applicability of the remaining portions of TSTF-585 to the

[PLANT] TS.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-585, " Revise LCO 3.0.3 to Require Managing Risk,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT

NAME, UNIT NOS] Technical Specifications (TS). TSTF-585 revises Limiting Condition for

Operation (LCO) 3.0.3 to require a risk assessment to be performed and risk management actions

to be implemented within six hours. If the risk assessment determines that continued plant

operation is acceptable and other conditions are satisfied, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from entry into LCO 3.0.3 is

permitted to initiate a shutdown. Otherwise, initiation of the shutdown is required immediately.

The proposed amendment also revises or adds some TS Required Actions to direct a plant

shutdown instead of entry into LCO 3.0.3.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed

amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of

amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or

consequences of an accident previously evaluated?

Response: No

The proposed change revises LCO 3.0.3 to provide additional time before initiating a

plant shutdown. The proposed change also revises or adds some TS Required Actions to

direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change does not affect the capability of any system to perform a design

function as assumed in previously evaluated accidents because the affected systems are

inoperable prior to entering LCO 3.0.3 or the Required Actions. The time permitted

before initiating a plant shutdown when Technical Specification requirements are not met

is not an assumption in any design basis accident or transient. Equipment that is

inoperable prior to an analyzed event is not an initiator of any accident previously

evaluated. Therefore, the probability of any accident previously evaluated is not affected.

The consequences of any design basis accident or transient that might occur during the

proposed period prior to initiation of a plant shutdown are no different than the

consequences of such an event during the current delay period provided by LCO 3.0.3.

The likelihood of malfunction of equipment is not affected as the applicable equipment is

DRAFT

TSTF-585, Rev. 3

Page 5

inoperable prior to entering LCO 3.0.3 or the Required Actions. As a result, the

consequences of previously evaluated accidents are not affected.

Therefore, the proposed change does not involve a significant increase in the probability

or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of

accident from any accident previously evaluated?

Response: No

The proposed change revises LCO 3.0.3 to provide additional time before initiating a

plant shutdown. The proposed change also revises or adds some TS Required Actions to

direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change only alters the time permitted before initiating a plant shutdown

when TS equipment is inoperable, or TS limits are not met. The proposed change does

not alter the design function or operation of any equipment because the affected systems

are inoperable prior to entering LCO 3.0.3 or the Required Actions. The design basis

accidents and transients considered in the updated final safety analysis report (UFSAR)

assume that equipment is operable at the beginning of the analysis, and the time

permitted to restore inoperable equipment or variables outside of limits is not an

assumption in the UFSAR in any design basis accident or transient analyses. Therefore,

providing a longer period after entering LCO 3.0.3 before initiating a plant shutdown or

adding Required Actions that direct a plant shutdown would not have been considered a

new or different design basis accident in the UFSAR if it had been previously identified.

Therefore, the proposed change does not create the possibility of a new or different kind

of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed change revises LCO 3.0.3 to provide additional time before initiating a

plant shutdown. The proposed change also revises or adds some TS Required Actions to

direct a plant shutdown instead of entry into LCO 3.0.3.

The proposed change only alters the time permitted before initiating a plant shutdown

when TS equipment is inoperable, or TS limits are not met. The proposed change does

not alter any specific values assumed in the design and licensing basis or controlling

values of parameters. The proposed change does not alter a design basis or safety limit.

Therefore, the proposed change does not involve a significant reduction in a margin of

safety.

DRAFT

TSTF-585, Rev. 3

Page 6

Based on the above, [LICENSEE] concludes that the proposed change presents no significant

hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a

finding of "no significant hazards consideration" is justified.

3.2 Conclusion

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that

the health and safety of the public will not be endangered by operation in the proposed manner,

(2) such activities will be conducted in compliance with the Commission’s regulations, and (3)

the issuance of the amendment will not be inimical to the common defense and security or to the

health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect

to installation or use of a facility component located within the restricted area, as defined in

10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed

amendment does not involve (i) a significant hazards consideration, (ii) a significant change in

the types or a significant increase in the amounts of any effluents that may be released offsite, or

(iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set

forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact

statement or environmental assessment need be prepared in connection with the proposed

amendment.

DRAFT

TSTF-585, Rev. 3

Technical Specifications and Bases Changes

DRAFT

LCO Applicability

3.0

Babcock & Wilcox STS 3.0-1 Rev. 5.0

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the

Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and

LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the

associated Conditions shall be met, except as provided in LCO 3.0.5 and

LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the

specified Completion Time(s), completion of the Required Action(s) is not

required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an

associated ACTION is not provided, or if directed by the associated

ACTIONS, the unit shall be placed in a MODE or other specified condition

in which the LCO is not applicable.

Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months perform a risk assessment addressing inoperable systems

and components and implement required risk management actions. If the

risk assessment determines that continuing operation is acceptable, the

required risk management actions are implemented, and entry into

LCO 3.0.3 was unplanned, then action Action shall be initiated within

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour to place the unit, as applicable, in:

a. MODE 3 within 307 hours0.00355 days 0.0853 hours 5.076058e-4 weeks 1.168135e-4 months ,

b. MODE 4 within 3613 hours0.0418 days 1.004 hours 0.00597 weeks 0.00137 months , and

c. MODE 5 within 6037 hours0.0699 days 1.677 hours 0.00998 weeks 0.0023 months .

If the risk assessment determines that continuing operation is not

acceptable, the risk assessment was not performed, the required risk

management actions were not implemented, or entry into LCO 3.0.3 was

planned, then action shall be initiated to place the unit, as applicable, in:

a. MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b. MODE 4 within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months , and

c. MODE 5 within 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months .

All times are determined from entry into LCO 3.0.3.

Exceptions to this Specification are stated in the individual Specifications.

If Where corrective measures are completed that permit operation in

accordance with the LCO or ACTIONS, then completion of the actions

required by LCO 3.0.3 is not required.

DRAFT TSTF-585, Rev. 3

LCO Applicability

3.0

Babcock & Wilcox STS 3.0-2 Rev. 5.0

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition

in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued

operation in the MODE or other specified condition in the

Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable

systems and components, consideration of the results,

determination of the acceptability of entering the MODE or other

specified condition in the Applicability, and establishment of risk

management actions, if appropriate (exceptions to this Specification

are stated in the individual Specifications); or

DRAFT TSTF-585, Rev. 3

APSR Alignment Limits

3.1.6

Babcock & Wilcox STS 3.1.6-1 Rev. 5.0

3.1 REACTIVITY CONTROL SYSTEMS

3.1.6 AXIAL POWER SHAPING ROD (APSR) Alignment Limits

LCO 3.1.6 Each APSR shall be OPERABLE and aligned within [6.5]% of its group

average height.

APPLICABILITY: MODES 1 and 2.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. One APSR inoperable,

not aligned within its

limits, or both.

A.1 Perform SR 3.2.3.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

AND

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each

APSR movement

B. Two or more APSRs

inoperable, not aligned

within their limits, or

both.

OR

Required Action and

associated Completion

Time not met.

B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.1.6.1 Verify position of each APSR is within [6.5]% of the

group average height.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

OR

In accordance

with the

DRAFT TSTF-585, Rev. 3

MSIVs

3.7.2

Babcock & Wilcox STS 3.7.2-1 Rev. 5.0

3.7 PLANT SYSTEMS

3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 Two MSIVs shall be OPERABLE.

APPLICABILITY: MODE 1,

MODES 2 and 3 except when all MSIVs are closed [and deactivated].

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. One MSIV inoperable in

MODE 1.

A.1 Restore MSIV to

OPERABLE status.

[8] hours

[OR

In accordance with

the Risk Informed

Completion Time

Program]

B. More than one MSIV

inoperable in MODE 1.

OR

Required Action and

associated Completion

Time of Condition A not

met.

B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

C. ------------NOTE------------

Separate Condition entry

is allowed for each

MSIV.

One or more MSIVs

inoperable in MODE 2

or 3.

C.1 Close MSIV.

AND

C.2 Verify MSIV is closed.

[8] hours

Once per 7 days

D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

DRAFT TSTF-585, Rev. 3

DC Sources - Operating

3.8.4

Babcock & Wilcox STS 3.8.4-2 Rev. 5.0

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. One DC electrical power

subsystem inoperable

for reasons other than

Condition A [or B].

C.1 Restore DC electrical

power subsystem to

OPERABLE status.

[2] hours

[OR

In accordance with

the Risk Informed

Completion Time

Program]

D. Required Action and

Associated Completion

Time of Condition A, B,

or C not met.

D.1 Be in MODE 3.

AND

D.2 --------------NOTE---------------

LCO 3.0.4.a is not

applicable when entering

MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

12 hours

E. Two DC electrical

power subsystems

inoperable.

E.1 Be in MODE 3.

AND

E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

36 hours

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.8.4.1 Verify battery terminal voltage is greater than or

equal to the minimum established float voltage.

[ 7 days

OR

In accordance

with the

Surveillance

Frequency

Control Program ]

DRAFT TSTF-585, Rev. 3

Distribution Systems - Operating

3.8.9

Babcock & Wilcox STS 3.8.9-2 Rev. 5.0

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. One or more DC

electrical power

distribution subsystems

inoperable.

C.1 Restore DC electrical

power distribution

subsystem(s) to

OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[OR

In accordance with

the Risk Informed

Completion Time

Program]

D. Required Action and

associated Completion

Time of Condition A, B,

or C not met.

D.1 Be in MODE 3.

AND

D.2 --------------NOTE---------------

LCO 3.0.4.a is not

applicable when entering

MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

12 hours

E. Two or more electrical

power distribution

subsystems inoperable

that result in a loss of

function.

E.1 Be in MODE 3.Enter

LCO 3.0.3.

AND

E.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

Immediately

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

DRAFT TSTF-585, Rev. 3

LCO APPLICABILITY

B 3.0

Babcock & Wilcox STS B 3.0-2 Rev. 5.0

BASES

LCO 3.0.2 (continued)

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. An example of this is in LCO 3.4.3, "RCS Pressure and

Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicable when

a system or component is removed from service intentionally. The

ACTIONS for not meeting a single LCO adequately manage any increase

in plant risk, provided any unusual external conditions (e.g., severe

weather, offsite power instability) are considered. In addition, the

increased risk associated with simultaneous removal of multiple

structures, systems, trains or components from service is assessed and

managed in accordance with 10 CFR 50.65(a)(4). Individual

Specifications may specify 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 from the point in time that the new Specification becomes

applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an

LCO is not met and either:

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.; or

c. Sometimes, possible combinations of Conditions are such that

entering LCO 3.0.3 is warranted; in such cases, tThe ACTIONS

specifically state a Condition corresponding to such combinations

and also that LCO 3.0.3 be entered immediately.

DRAFT TSTF-585, Rev. 3

LCO APPLICABILITY

B 3.0

Babcock & Wilcox STS B 3.0-3 Rev. 5.0

BASES

LCO 3.0.3 (continued)

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. Planned entry into LCO 3.0.3 should be avoided. If it is not

practicable to avoid planned entry into LCO 3.0.3, plant risk should be

assessed and managed in accordance with 10 CFR 50.65(a)(4), and the

planned entry into LCO 3.0.3 should have less effect on plant safety than

other practicable alternatives.

Upon entering LCO 3.0.3, a risk assessment addressing inoperable

systems and components must be completed and required risk

management actions must be implemented within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The risk

assessment must consider all inoperable 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

1.160, "Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants." Regulatory Guide 1.160 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 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). The likely cause of the conditions that resulted in LCO

3.0.3 entry should be understood. A formal cause or apparent cause

evaluation is not required because of the limited time available. If

the extent of condition is unknown, the risk assessment should

consider the increased possibility of common cause failure either

numerically or through risk management actions.

If the risk assessment determines that there is no more than a

minimal increase in risk after implementation of risk management

actions (i.e., the level determined acceptable during normal work

control levels as discussed in Section 11 of NUMARC 93-01), then

continuing operation for a limited time is acceptable. Provided that

the risk assessment determined that continuing operation is

acceptable, that the required risk management actions are

implemented, and that entry into LCO 3.0.3 was unplanned, action to

shut down the unit must be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entry into

LCO 3.0.3. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period may be used to perform repairs,

prepare for an orderly plant shutdown, or to pursue regulatory relief.

DRAFT TSTF-585, Rev. 3

LCO APPLICABILITY

B 3.0

Babcock & Wilcox STS B 3.0-4 Rev. 5.0

It is not necessary for the planned restoration of compliance with

the LCO or ACTIONS to be within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as other actions are

available, such as regulatory relief or an orderly shutdown. The

term “required risk management actions” means those risk

management actions that are quantitatively or qualitatively credited

in the risk assessment and are necessary for the risk assessment to

demonstrate that continued plant operation is acceptable. The 24

hour provision may not be used if the LCO 3.0.3 entry is planned,

such as intentionally removing a train from service when the

redundant train is inoperable. However, it may be used for emergent

conditions that occur in parallel with other planned or unplanned

inoperabilities.

If the risk assessment determines that continuing operation is not

acceptable, if the risk assessment was not completed or the

required risk management actions were not implemented, or if entry

into LCO 3.0.3 was planned, action to shut down the unit must be

initiated following the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period provided to perform the

risk assessment and implement risk management actions.

All times for completing actions and entering MODES are

determined from entry into LCO 3.0.3.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 enter lower MODES of operation permit the

shutdown to proceed in a controlled and orderly manner that is well within

the specified maximum cooldown rate and within the capabilities of the

unit, assuming that 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 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.

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 is now met,

b. The LCO is no longer applicable,

c. A Condition exists for which the Required Actions have now been

performed, or

d. ACTIONS exist that do not have expired Completion Times. These

Completion Times are applicable from the point in time that the

DRAFT TSTF-585, Rev. 3

LCO APPLICABILITY

B 3.0

Babcock & Wilcox STS B 3.0-5 Rev. 5.0

Condition is initially entered and not from the time LCO 3.0.3 is

exited.

The time limits of LCO 3.0.3 allow 3637 hours0.0421 days 1.01 hours 0.00601 weeks 0.00138 months for the unit to be in

MODE 5 when after a shutdown is initiated required during MODE 1

operation. If the unit is in a lower MODE of operation when a shutdown is

requiredinitiated, the time limit for entering the next lower MODE applies.

If a lower MODE is entered in less time than allowed, however, the total

allowable time to enter MODE 5, or other applicable MODE, is not

reduced. For example, if MODE 3 is entered in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after a

shutdown is initiated, then the time allowed for entering MODE 4

BASES

LCO 3.0.3 (continued)

is the next 1011 hours0.0117 days 0.281 hours 0.00167 weeks 3.846855e-4 months , because the total time for entering MODE 4 is not

reduced from the allowable limit of 1213 hours0.014 days 0.337 hours 0.00201 weeks 4.615465e-4 months after a shutdown is

initiated. Therefore, if remedial measures are completed that would

permit a return to MODE 1, a penalty is not incurred by having to enter 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 by LCO 3.0.3. 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 3.7.14, "Fuel Storage Pool Water Level." LCO 3.7.14

has an Applicability of "During movement of irradiated fuel assemblies in

fuel storage pool." Therefore, this LCO can be applicable in any or all

MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met

while in MODE 1, 2, 3, or 4, there is no safety benefit to be gained by

placing the unit in a shutdown condition. The Required Action of

LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in fuel

storage 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 LCO 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 either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

DRAFT TSTF-585, Rev. 3

APSR Alignment Limits

B 3.1.6

Babcock & Wilcox STS B 3.1.6-3 Rev. 5.0

BASES

ACTIONS A.1

The ACTIONS described below are required if one APSR is inoperable.

The plant is not allowed to operate with more than one inoperable APSR.

This would require the reactor to be shut down, in accordance with

LCO 3.0.3.

An alternate to realigning a single misaligned APSR to the group average

position is to align the remainder of the APSR group to the position of the

misaligned or inoperable APSR, while maintaining APSR insertion, in

accordance with the limits in the COLR. This restores the alignment

requirements. Deviations up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will not cause significant xenon

redistribution to occur. This alternative assumes the APSR group

movement does not cause the limits of LCO 3.2.2, "AXIAL POWER

SHAPING ROD (APSR) Insertion Limits," to be exceeded. For this

reason, APSR group movement is only practical for instances where

small movements of the APSR group are sufficient to re-establish APSR

alignment.

The reactor may continue in operation with the APSR misaligned if the

limits on AXIAL POWER IMBALANCE are surveilled within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to

determine if the AXIAL POWER IMBALANCE is still within limits. Also,

since any additional movement of the APSRs may result in additional

imbalance, Required Action A.1 also requires the AXIAL POWER

IMBALANCE Surveillance to be performed again within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after

each APSR movement. The required Completion Time of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

will not cause significant xenon redistribution to occur.

B.1

The plant must be brought to a MODE in which the LCO does not apply if

more than one APSR is inoperable, or is misaligned, or both, or the

Required Actions and associated Completion Times cannot be met. To

achieve this status, the plant must be brought to at least MODE 3 within

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on

operating experience, for reaching MODE 3 from RTP in an orderly

manner and without challenging plant systems. In MODE 3, APSR group

alignment limits are not required because the reactor is not generating

THERMAL POWER and excessive local LHRs cannot occur from APSR

misalignment.

DRAFT TSTF-585, Rev. 3

MSIVs

B 3.7.2

Babcock & Wilcox STS B 3.7.2-4 Rev. 5.0

BASES

ACTIONS (continued)

B.1

If the MSIV cannot be restored to OPERABLE status in accordance with

Required Action A.1, or if more than one MSIV is inoperable in MODE

1, the unit must be placed in MODE 2 and the inoperable MSIV(s) closed

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Times are reasonable, based on

operating experience, to reach MODE 2.

C.1 and C.2

Condition C is modified by a Note indicating that separate Condition entry

is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the

inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the

assumptions in the safety analysis.

The [8] hour Completion Time is consistent with that allowed in

Condition A.

Inoperable MSIVs that cannot be restored to OPERABLE status within

the specified Completion Time, but are closed, must be verified on a

periodic basis to be closed. This is necessary to ensure that the

assumptions in the safety analysis remain valid. The 7 day Completion

Time is reasonable, based on engineering judgment, in view of MSIV

status indications available in the control room, and other administrative

controls, to ensure these valves are in the closed position.

D.1 and D.2

If the MSIV cannot be restored to OPERABLE status or closed in the

associated Completion Time, the unit must be placed in a MODE in which

the LCO does not apply. To achieve this status, the unit must be placed

in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The

allowed Completion Times are reasonable, based on operating

experience, to reach the required unit conditions from MODE 2 conditions

in an orderly manner and without challenging unit systems.

DRAFT TSTF-585, Rev. 3

DC Sources - Operating

B 3.8.4

Babcock & Wilcox STS B 3.8.4-8 Rev. 5.0

BASES

ACTIONS (continued)

D.1 and D.2

If the inoperable DC electrical power subsystem(s) cannot be restored to

OPERABLE status within the required Completion Time, the unit must be

brought to a MODE in which overall plant risk is minimized. To achieve

this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable because the

plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). There

are more accident mitigation systems available and there is more

redundancy and diversity in core heat removal mechanisms in MODE 4

than in MODE 5. For example, in MODE 4 the turbine driven emergency

feedwater pump[s] are available to provide Reactor Coolant System

(RCS) cooling via the steam generators utilizing natural circulation.

However, voluntary entry into MODE 5 may be made as it is also an

acceptable low-risk state.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is

not applicable when entering MODE 4. This Note prohibits the use of

LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable,

because LCO 3.0.4.b requires performance of a risk assessment

addressing inoperable systems and components, consideration of the

results, determination of the acceptability of entering MODE 4, and

establishment of risk management actions, if appropriate. LCO 3.0.4 is

not applicable to, and the Note does not preclude, changes in MODES or

other specified conditions in the Applicability that are required to comply

with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating

experience, to reach the required unit conditions from full power

conditions in an orderly manner and without challenging plant systems.

E.1 and E.2

If both DC electrical power subsystems are inoperable, the plant

must be brought to a MODE in which the LCO does not apply. To

achieve this status, the plant must be brought to at least MODE 3

within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed

Completion Times are reasonable, based on operating experience,

to reach the required plant conditions from full power conditions in

an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.4.1

DRAFT TSTF-585, Rev. 3

Distribution Systems - Operating

B 3.8.9

Babcock & Wilcox STS B 3.8.9-7 Rev. 5.0

BASES

ACTIONS (continued)

results, determination of the acceptability of entering MODE 4, and

establishment of risk management actions, if appropriate. LCO 3.0.4 is

not applicable to, and the Note does not preclude, changes in MODES or

other specified conditions in the Applicability that are required to comply

with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating

experience, to reach the required unit conditions from full power

conditions in an orderly manner and without challenging plant systems.

E.1and E.2

Condition E corresponds to a level of degradation in the electrical

distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem

results in the loss of a required function, the unit must be brought to a

MODE in which overall plant risk is reduced. To achieve this status, the

unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .the plant is in a condition outside the accident analysis.

Therefore, no additional time is justified for continued operation.

LCO 3.0.3 must be entered immediately to commence a controlled

shutdown.

SURVEILLANCE SR 3.8.9.1

REQUIREMENTS

This Surveillance verifies that the [required] AC, DC, and AC vital bus

electrical power distribution systems are functioning properly, with the

correct circuit breaker alignment. The correct breaker alignment ensures

the appropriate separation and independence of the electrical divisions is

maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that

the required voltage is readily available for motive as well as control

functions for critical system loads connected to these buses. [ The 7 day

Frequency takes into account the redundant capability of the AC, DC, and

AC vital bus electrical power distribution subsystems, and other

indications available in the control room that alert the operator to

subsystem malfunctions.

OR

The Surveillance Frequency is controlled under the Surveillance

Frequency Control Program.

DRAFT TSTF-585, Rev. 3

LCO Applicability

3.0

Westinghouse STS 3.0-1 Rev. 5.0

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the

Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and

LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the

associated Conditions shall be met, except as provided in LCO 3.0.5 and

LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the

specified Completion Time(s), completion of the Required Action(s) is not

required unless otherwise stated.