BSEP 02-0002, Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process

From kanterella
Jump to navigation Jump to search
Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process
ML020860428
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 03/25/2002
From: Keenan J
Carolina Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 02-0002, TSC-2001-12
Download: ML020860428 (21)
v • d • e


Text

~ CP&Loon AProgress nergy kr Company John S. Keenan Vice President Brunswick Nuclear Plant M 2 5 2002 10 CFR 50.90 SERIAL: BSEP 02-0002 TSC-2001-12 U. S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Carolina Power & Light (CP&L)

Company is submitting a request for amendments to the Technical Specifications (TSs) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed license amendments would modify TS requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3.

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachments 2 and 3 provide the existing Units 1 and 2 TS pages marked up to show the proposed change. Attachments 4 and 5 provide revised (typed) Units 1 and 2 TS pages. Attachment 6 provides a summary of the regulatory commitments made in this submittal. Attachment 7 provides the existing TS Bases pages marked up to show the proposed change (for information only).

CP&L requests approval of the proposed license amendments by September 9, 2002, with the amendments being implemented within 60 days of issuance of the amendments.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to Mr. Mel Fry of the State of North Carolina.

P.O.Box 10429 Southport, NC 28461 T> 910.457.2496 DO S> 910.457.2803

Document Control Desk BSEP 02-0002 / Page 2 Please refer any questions regarding this submittal to Mr. David C. DiCello, Manager - Regulatory Affairs, at (910) 457-2235.

Sincerely, S. Keenan CRE/cre Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes for Unit 1
3. Proposed Technical Specification Changes for Unit 2
4. Revised Technical Specification Pages for Unit 1
5. Revised Technical Specification Pages for Unit 2
6. Regulatory Commitments
7. Proposed Technical Specification Bases Changes for Unit Nos. I and 2 John S. Keenan, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; "andthe sources of his information are officers, employees, and agents of Carolina Power &

Light Company.

Notary (Seal)

My commission expires:

Document Control Desk BSEP 02-0002 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Mel Fry Director - Division of Radiation Protection North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TSs) requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3.

The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-358 Revision 5, as modified by Federal Register Notice 66FR32400, of June 14, 2001, and in response to public comments. The availability of this TS improvement was published in the FederalRegister on September 28, 2001, as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Carolina Power & Light (CP&L) Company has reviewed the safety evaluation dated September 28, 2001, as part of the CLHIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-358. CP&L has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, and justify these amendments for the incorporation of the changes to the B SEP, Unit Nos.

l and 2 TSs.

2.2 Optional Chanp-es and Variations CP&L is not proposing any variations or deviations from the TS changes described in the fully modified TSTF-358 Revision 5 or the NRC staff's model safety evaluation dated September 28, 2001.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination CP&L has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister as part of the CLIIP. CP&L has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to BSEP, Unit Nos. 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Al-I

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on September 28, 2001, for this TS improvement, plant-specific verifications were performed as follows:

CP&L has established TS Bases for SR 3.0.3 which state that use of the delay period established by Surveillance Requirement 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.

The modification will also include changes to the Bases for SR 3.0.3 that provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes will state that CP&L is expected to perform a missed surveillance at the first reasonable opportunity, taking into account appropriate considerations, such as impact on plant risk and analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases will also state that the 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 Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases will state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases will also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases will state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, CP&L has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.

4.0 Environmental Evaluation CP&L has reviewed the environmental evaluation included in the model safety evaluation dated September 28, 2001, as part of the CLIIP. CP&L has concluded that the staff's findings presented in that evaluation are applicable to BSEP, Unit Nos. 1 and 2, and the evaluation is hereby incorporated by reference for this application.

A1-2

ATTACHMENT 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION CHANGES FOR UNIT 1

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREHENT (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 Cerform a Surveillance within the specified Frequency shall e 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 stateA his e individual Specifications. a SR 3.0.3 If ttts discovered that a Surveillance was not performed antotheSurveillance within ts specified Frequency, i o LCethe then com liancdewith o te daeyb ri'S. '

rt* vqlqtj,, (, ( drequclrement the time of discovery, met, dta the alicable up to Cmay. to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s] thefutb the melayed, limit of

  • the specified Frequency, whichever is, :_ This delay

(~ero * *ttted f Is per'mi¢ to allow performance of the

+

e- euvllac If the Surveillance is not performed within the delay c *+cr 4%* .q period, the LCO must Immediately be declared not met, and

-+ý rskjrhp;L the applicable Condition(s) must be entered.

  • v miq*,.
  • Il* J When the Surveillance is performed within the delay period 5ý,0 be-metc4, edand the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Brunswick Unit I 3.0-4 Amendment No. 2Oe-

ATTACHMENT 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324ALICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION CHANGES FOR UNIT 2

SR Applicabil ity 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 erform a Surveillance within the specified Frequency shall e 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,o 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 individual to this Specification are stated in t h.e Specifications.

SR303If ittis discovered that a Surveillance was not performed

  • within its specified Frequency, then com iacwith the fA sk tcv-q1Act+,c- 5kqII requirement to declare the LCO not me may e 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 /> r up to the limit of be rcrfor, c(fc,- qoy the specified Frequency, whichever is, . This delay i ***-t*1* .* :*¢ weriod is 'ermitted IftheSurveillanceA to allow performance of the If the Surveillance is not performed within the delay

&i-iJ+Lie. r5K t'.t

  • 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)

Brunswick Unit 2 3.0-4 Amendment No. 33-

ATTACHMENT 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS REVISED TECHNICAL SPECIFICATION PAGES FOR UNIT 1

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 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 I period is permitted to allow performance of the Surveillance. 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)

Brunswick Unit 1 3.0-4 Amendment No. I

ATTACHMENT 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS REVISED TECHNICAL SPECIFICATION PAGES FOR UNIT 2

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 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 "Konce 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 I period is permitted to allow performance of the Surveillance. 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 I

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)

Brunswick Unit 2 3.0-4 Amendment No. I

ATTACHMENT 6 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS REGULATORY COMMITMENTS The table below lists actions committed to by Carolina Power & Light (CP&L) Company in this document. Any other actions discussed in this submittal represent intended or planned actions by CP&L. They are described for the NRC's information and are not regulatory commitments.

Please notify the Manager - Regulatory Affairs at the Brunswick Steam Electric Plant of any questions regarding this document or any associated regulatory commitments.

REGULATORY COMMITMENT DUE DATE/EVENT CP&L will establish Technical Specification Bases for SR 3.0.3 as Implemented with adopted with the applicable license amendments. amendments.

ATTACHMENT 7 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION BASES CHANGES FOR UNIT NOS. 1 AND 2

SR Applicability B 3.0 BASES (continued)

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified imits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified (continued) Frequency, whichever i4L),

BASES applies from the point in time I 1 I 4er 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 complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion 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.

rwhen a Surfeilla 6e wit 'a Fre uencyv*ased 9,6t on $me /

interval , but on sp cifieunit c6nditits or ferati hal situatins, is discov red n9 to hAie bee perfo d wh n t~i~ cvIV% speci ed, S 3.0.3 l1ows he fu 1 del peria of 2/hours to p arm e Sur eillan e.

S 3.0.3 iso pevides time mit 0 r co etion of rveil nces at e e cabl as a onseq nce of 0o E c anges Jmposed y Re ired tions 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 as an operational convenience to extend K~e~V,~2 Surveillance Intervafs.A I 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 (conti nued)

Brunswick Unit I B 3.0-13 Revision No. b I

Brunswick Unit 1 TS Bases Page B 3.0-13 Inserts Insert 1 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 2 While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.

SR Applicability B 3.0 BASES SR 3.0.3 delay period. If a Surveillance Is failed within the delay (continued) 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.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition In the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry Into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

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

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a RODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside Its specified limits, the associated SR(s) are not required to be performed per SR 3.0.1, which states that Surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed Is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency, on equipment that Is inoperable, does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the*LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

(continued)

Brunswick Unit I B 3.0-14 Revision No. @ I

SR Applicability B 3.0 BASES (continued)

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 completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> .or.up to the limit of the specified Frequency, whichever I applies from the point in I timethat it is discove'ed 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 complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion 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.

rl n a rvei ance with 4 Fre en -base 'not on tim Iterv:s, bt upo speq fled (nt condi'ons or oper tiona istua ons, is di cover d no to ave b en performed when spec ledSR3. .3 alows e f 1de per od of24 ho s CTrsev-t I i v3.0alsq provles a/line itt or co pletio of /

..urve .lancZt tha/beco *e ap icabl as a onse ence f MWODE hange impq ed b Re red Ations/

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 as an operational convenience to extend Surveillance intervals. X I 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 (continued)

Brunswick Unit 2 8 3.0-13 Revision No. @ I

Brunswick Unit 2 TS Bases Page B 3.0-13 Inserts Insert 1 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 2 While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.

SR Applicability B 3.0 BASES SR 3.0.3 delay period. If a Surveillance is failed within the delay (continued) 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.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry Into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

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

However, In certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed per SR 3.0.1, which states that Surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency, on equipment that is Inoperable, does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes.

(continued)

Brunswick Unit 2 B 3.0-14 Revision No.@ I

Retrieved from "https://kanterella.com/w/index.php?title=BSEP_02-0002,_Application_for_Technical_Specification_Change_Regarding_Missed_Surveillance_Using_the_Consolidated_Line_Item_Improvement_Process&oldid=2708343"