ET 19-0001, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4

Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4

ML19036A772
Person / Time
Site:	Wolf Creek
Issue date:	01/23/2019
From:	Shawn Smith Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 19-0001
Download: ML19036A772 (31)

Text

Stephen L Smith January 23, 201'9 Vice President Engineering ET 19-0001 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: Application to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4 To Whom It May Concern:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License Number NPF-42 for the Wolf Creek Generating Station (WCGS). The license amendment request (LAR) proposes to revise Technical Specification (TS) 3.0.3.

The proposed amendment would modify TS requirements in Section 1.3 regarding Completion Times and Section 3.0 regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with Nuclear Regulatory Commission (NRC) approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22(b), "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment. The amendment application was reviewed by the WCNOC Plant Safety Review Committee.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this amendment application is being provided to the designated Kansas State official.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 19-0001 Page 2 of 3 There are no regulatory commitments contained .in this submittal.

Attachment I provides an Evaluation of Proposed Changes. Attachment II provides the Proposed Technical Specification Changes (Mark-Up) Pages. Attachment Ill provides the Retyped Technical Specification Pages. Attachment IV provides the Proposed Technical Specification Bases Changes (Mark-Up) (for information oniy). Final TS Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specifications (TS) Bases Control Program," at the time the amendment is implemented.

WCNOC requests approval of this proposed license amendment by Januaryr 3, 2020. The changes proposed are not required to address an immediate safety concern. It is anticipated that the license amendment, as approved, will be effective upon issuance, to be implemented within 90 days from the date of issuance. If you have any questions concerning this matter, please contact me at (620) 364-4093, or Ron Benham at (620) 364-4204.

Sincerely, Stephen L. Smith SLS/rlt Attachments: I Evaluation of Proposed Changes II - Proposed Technical Specification Changes (Mark-Up) Pages Ill - Retyped Technical Specification Pages IV - Proposed Technical Specification Bases Changes (Mark-Up) (for information only) cc: . S. A Morris (NRC), w/a B. K. Singal (NRC), w/a K. S. Steves (KDHE), w/a N. H. Taylor (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 19-0001 Page 3 of 3 STATE OF KANSAS )

) ss COUNTY OF COFFEY )

Stephen L. Smith, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By---==-~---==--'-=-=--~~

Stephen L. Smith Vice President Engineering SUBSCRIBED and sworn to before me this .J.3~y of -:Jiinuo.....f'-y , 2019.

@h,oncLa.

Notary Public Expiration Date.}inun r:: \/( 11.; :JO J 'J

Attachment I to ET 19-0001 Page 1 of 5 ATTACHMENT I EVALUATION OF PROPOSED CHANGES

Attachment I to ET 19-0001 Page 2 of 5 EVALUATION OF PROPOSED CHANGES

Subject:

Application to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4.

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination

4.0 ENVIRONMENTAL CONSIDERATION

\_

Attachment I to ET 19-0001 Page 3 of 5 EVALUATION OF PROPOSED CHANGES

1.0 DESCRIPTION

The proposed changes revise Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

• Section 1.3 is revised to clarify "discovery."

• Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

• Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

• Surveillance Requirement (SR) 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0:3.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation

• Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016.

This review included a review of the Nuclear Regulatory Commission (NRC) staff's evaluation, as well as the information provided in. Technical Specification Task Force, TSTF-529. As described in the subsequent paragraphs, WCNOC has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to Wolf Creek Generating Station (WCGS) and justify this amendment for the incorporation of the changes to the WCGS TSs.

2.2 Variations For WCGS, WCNOC is not proposing any variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staff's safety evaluation dated April 21, 2016.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

. Wolf Creek Nuclear Operating Corporation (WCNOC) requests adoption of TSTF-529, "Clarify Use and Application Rules," that is an approved change to the standard technical specifications (STS), into the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" *of the TS to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Conditio11 for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change

Attachment I to ET 19-0001 Page 4 of 5 is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed. WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to Section 1.3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed change does not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Attachment I to ET 19-0001 Page 5 of 5 Based on the above, WCNOC 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or 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 change 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 change.

Attachment II to ET 19-0001 Page 1 of 5 ATTACHMENT II PROPOS ED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment II to ET 19-0001 Page 2 of 5 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action . It is referenced to the time of discovery of a situation (e.g. , inoperable equipment or variable not with in limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions) , the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time ef discovery of the situation that required entry into the Condition:-, unless otherwise specified .

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition , discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated . The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.,., unless otherwise specified .

(continued)

Wolf Creek - Unit 1 1.3-1 Amendment No. ~

Attachment II to ET 19-0001 Page 3 of 5 INSERT 1.3-1 Unless otherwise specified , the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time.

While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1 , "AC Sources - Operating ," Required Action 8.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Attachment II to ET 19-0001 LCO Applicability Page 4 of 5 3.0 3.0 LCO Applicability LCO 3.0.4 specified condition in the Applicability, and establishment of risk (continued) management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification .

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1 .8, allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified , all other TS requirements remain unchanged . Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

(continued)

Wolf Creek - Unit 1 3.0-2 Amendment No. 123, 155, 473

Attachment II to ET 19-0001 SR Applicability Page 5 of 5 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed . A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

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

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

(continued)

Wolf Creek - Unit 1 3.0-4 Amendment No. 123, 14 a, 4-73

Attachment Ill to ET 19-0001 Page 1 of 5 ATTACHMENT Ill RETYPED TECHNICAL SPECIFICATION PAGES

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g ., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied , such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) ." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied .

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions) , the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that (continued)

Wolf Creek - Unit 1 1.3-1 Amendment No. ~

Completion Times 1.3 1.3 Completion Time DESCRIPTION required entry into the Condition, unless otherwise specified .

(continued)

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition , unless specifically stated . The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified .

However, when a subsequent train , subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended . To apply this Completion Time extension, two criteria must first be met. The subsequent in operability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition , plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train , subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery ... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended .

(continued)

Wolf Creek - Unit 1 1.3-2 Amendment No. ~

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 specified condition in the Applicability, and establishment of risk (continued) management actions, if appropriate; (exceptions to this Specification are stated in the individual Specifications); or C. When an allowance is stated in the individual value, parameter, or other Specification .

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered . Only the support system LCO ACTIONS are required to be entered . This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by th is program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered .

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

(continued)

Wolf Creek - Unit 1 . 3.0-2 Amendment No. 123, 155, ~

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the

~CO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once ," the above interval extension does not apply.

If a Completion Time requires period ic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed , from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed .

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

When the Surveillance is performed with in the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Wolf Creek - Unit 1 3.0-4 Amendment No. 12a, 14J, 47d

Attachment IV to ET 19-0001 Page 1 of 13 ATTACHMENT IV PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP) (FOR INFORMATION ONLY)

Attachment IV to ET 19-0001 LCO Applicability Page 2 of 13 B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABIL TY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e. , when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered,.,.. unless otherwise specified .

The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Wolf Creek - Unit 1 B 3.0-1 Revision 34

Attachment IV to ET 19-0001 LCO Applicability Page 3 of 13 B 3.0 BASES LCO 3.0.3 b. The condition of the unit is not specifically addressed by the (continued) associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to enter feaGR-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.

cb. A Condition exists for which the Required Actions have now been performed .

dG. ACTIONS exist that do not have expired Completion Times.

These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited .

Wolf Creek - Unit 1 B 3.0-3 Revision G

Attachment IV to ET 19-0001 Page 4 of 13 LCO Applicability B 3.0 BASES LCO 3.0.3 The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in (continued) MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering reasRiRg the next lower MODE applies. If a lower MODE is entered reasReEI in less time than allowed, however, the total allowable time to enter feaGA-MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is entered reasReEI in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering reasRiRg MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for entering reasRiRg MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter f8aGh-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 3.7.15, "Fuel Storage Pool Water Level." LCO 3.7.15 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.15 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 .15 of "Suspend movement of irradiated fuel assemblies in the 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 LCO either 3.0.4a., LCO 3.0.4b., or LCO 3.0.4c.

Wolf Creek - Unit 1 B 3.0-4 RevisionW

Attachment IV to ET 18-0030 LCO Applicability Page 5 of 13 B 3.0 BASES LCO 3.0.4 LCO 3.0.4a. allows entry into a MODE or other specified condition in the (continued) Applicability with the LCO not met when the associated ACTIONS to be entered permit oontin1:1ed operation in following entry into the MODE or other specified cond ition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with Req1:1ired Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation.

This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made and the Required Actions followed after entry into the Applicability. in aooorElanoe witR tRe pF8¥isions of tRe Req1:1ired Actions.

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

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed . The risk assessment, for the purposes of LCO 3.0.4b., must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. " Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01 , "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

Wolf Creek - Unit 1 B 3.0-5 Revision4G

Attachment IV to ET 19-0001 Page 6 of 13 INSERT B 3.0-5 For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time.

Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

Attachment IV to ET 19-0001 LCO Applicability Page 7 of 13 B 3.0 BASES LCO 3.0.4 as a change in MODE or other specified condition in the Applicability (continued) associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, MODE 4 to MODE 5, and MODE 5 to MODE 6.

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

Surveillances do not have to be perfonned on the associated inoperable equipment (or on variables outside the specified limits), as pennitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS . The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g. , to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.

AR exam13le ef aemeRstFatiRg tt:le OP!;;RAQlblTY ef tt:le eq1,1i13meRt eeiRg Fet1>1FRea ta seFVise is Feai;>eRiRg a saRtaiRmeRt isalatieR val\*e tt:iat t:ias eeeR slesea te sam13ly witt:l Req1,1iraa AstieRs aRa m1,1st ee Fee13eRea ta 13eFfaFm tt:ie F0E11>1iFea testiRg .

INSERT B.3.0-7 ExamplesAR exam13le of demonstrating the OPERABILITY of other equipment areffi taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of Wolf Creek - Unit 1 B 3.0-7 Revision 4-9

Attachment IV to ET 19-0001 Page 8 of 13 INSERT B 3.0-7 LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

Attachment IV to ET 19-0001 LCO Applicability Page 9 of 13 B 3.0 BASES LCO 3.0.5 required testing on another channel in the other trip system ,~ or 2) A (continued) similaf eMample of Elemonstrating the OPERABILITY of other eqwipment is takinan inoperaele channel or trip system owt of the trippeel conelition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip INSERT B.3.0-8 system.

LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (TS). This exception is provided because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Actions. These Required Actions may include entering the supported system's Conditions and Required Actions or may specify other Required Actions. When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Conditions and Required Actions unless directed to do so by the support system's Required Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.

However, there are instances where a support system's Required Action may either direct a supported system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system.

This may occur immediately or after some specified delay to perform some other Required Action . Regardless of whether it is immediate or after some delay, when a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

Specification 5.5.15, "Safety Function Determination Program (SFDP) ,"

ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Conditions and Required Actions. The SFDP implements the requirements of LCO 3.0.6.

Wolf Creek - Unit 1 B 3.0-8 Revision 49

Attachment IV to ET 19-0001 Page 10 of 13 INSERT B 3.0-8 The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

Attachment IV to ET 19-0001 SR Applicability Page 11 of 13 8 3.0 BASES SR 3.0.2 the function of the inoperable equipment in an alternative manner.

(continued)

The provisions of SR 3.0.2 are not intended to be used repeatedly ffi8fely as aA epeFatieAal seAveAieAse to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed 68Fflpleted within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to perform 68Fflplete Surveillances that have been missed. This delay period permits the performance seFflpletieA of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance 68FflpletieA of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements . When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

INSERT B.3.0-13 Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly as aA eperatieAal Wolf Creek - Unit 1 8 3.0-13 Revision 34

Attachment IV to ET 19-0001 Page 12 of 13 INSERT B 3.0-13 SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

Attachment IV to ET 19-0001 SR Applicability Page 13 of 13 B 3.0 BASES SR 3.0.3 convenience -to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the (continued) limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.*

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

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

Wolf Creek - Unit 1 B 3.0-14 Revision 34