LR-N02-0027, PSEG Nuclear, Llc., Application for Amendment to Licenses DPR-70 to Change TS Missed Surveillance Requirements (T.S. 4.0.3) & Adoption of TS Bases Control Program

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PSEG Nuclear, Llc., Application for Amendment to Licenses DPR-70 to Change TS Missed Surveillance Requirements (T.S. 4.0.3) & Adoption of TS Bases Control Program
ML022190314
Person / Time
Site: Salem  PSEG icon.png
Issue date: 07/25/2002
From: Garchow D
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR S02-02, LR-N02-0027
Download: ML022190314 (21)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 WO PSEG VJL25 20U \

Nuclear LLLC LR-N02-0227 LCR S02-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REGARDING MISSED SURVEILLANCE REQUIREMENTS (T.S. 4.0.3) AND ADOPTION OF TS BASES CONTROL PROGRAM (T.S. 6.5) USING CLIIP SALEM GENERATING STATION UNIT NOS. I AND 2 DOCKET NOS. 50-272, 50-311 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 Gentlemen:

In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) and supporting Bases for Salem Generating Station Unit Nos. 1 and 2. The proposed amendment would modify TS requirements for missed surveillance tests in TS 4.0.3 using the Consolidated Line Item Improvement Process (CLIIP),

described in NRC approved industry Technical Specification Task Force (TSTF) change TSTF-358, Revision 6. In conjunction with this change, the submittal incorporates a TS Bases Control Program in TS Section 6.0 consistent with the program described in the Standard Technical Specifications for Westinghouse Plants (STS), NUREG-1431, Revision 2, 4/30/01. provides a description of the proposed change, the requested confirmation of applicability and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. summarizes the regulatory commitments made in this submittal and Attachment 4 provides the existing TS Bases pages marked up to show the proposed changes. Pursuant to the STS requirements for TS Bases control, as incorporated into this Amendment request, the revised Bases are being submitted for NRC review and approval.

95-2168 REVý 7/99

Document Control Desk UJUL 2 5 2002 LR-N02-0227 The Station Operations Review Committee (SORC) and the Nuclear Review Board (NRB) have reviewed the proposed amendment. Pursuant to the requirements of 10 CFR 50.91(b)(1), a copy of this request for amendment has been sent to the State of New Jersey.

PSEG requests approval of the proposed license amendment by January 31, 2003, to be implemented within 60 days of receipt by PSEG. The requested date is not needed to support a specific operational activity.

Should you have any questions regarding this request, please contact Carl Berger at (856) 339-1432.

I declare underpenalty of perdury under the laws of the United States of America that I am authorizedby PSEG Nuclear,LLC to make this request and that the foregoing is true and correct.

Sincerely, Vice President - Operations : Description and Assessment : Marked-up TS Pages : List of Regulatory commitments : Proposed Changes to TS Bases Pages

UL 2 5 2002 Document Control Desk LR-N02-0227 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. R. Fretz, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission Mail Stop 08B2 Washington, DC 20555-0001 USNRC Resident Inspector Office (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

ATTACHMENT 1 LCR S02-02 LR-N02-0227 SALEM GENERATING STATION UNIT NOS. I AND 2 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM DESCRIPTION AND ASSESSMENT

1. DESCRIPTION The proposed amendments would modify technical specification requirements for a missed surveillance as delineated in Surveillance Requirement (SR) 4.0.3. The changes are consistent with the Industry Technical Specification Task Force (TSTF) change on missed surveillances,TSTF-358, Revision 6, approved by the NRC on October 3, 2001 (Ref. 1). The TSTF, along with a supporting model safety evaluation and proposed No Significant Hazards Consideration Determination, were initially published in Federal Register Notice 66FR32400, dated June 14, 2001, as part of the Consolidated Line Item Improvement Process (CLIIP). Revision 6 incorporates subsequent NRC Staff review and public comments as provided in the notice of availability published in the Federal Register on September 28, 2001 (Ref. 2).

In conjunction with this change, the submittal incorporates a TS Bases Control Program into Section 6.0, consistent with the program described in the Standard Technical Specifications for Westinghouse Plants (STS), NUREG-1431, Revision 2, 4/30/01.

2. ASSESSMENT Applicability of published Safety Evaluation PSEG has reviewed the safety evaluation published in Federal Register 66FR32400 dated June 14, 2001, which supports the CLIIP. This review included a review of the NRC staffs evaluation, as well as supporting information provided for TSTF-358. PSEG has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by NRC staff are applicable to Salem Units 1 and 2 and justify these amendments for incorporation of the changes into the plants' technical specifications.

Optional Changes and Variations PSEG is proposing minor conforming variations from the TS changes described in TSTF-358, Revision 6. Salem Units 1 and 2 have not adopted Standard Technical Specifications; therefore, SR 3.0.3 is actually SR 4.0.3 and the administrative requirements are located under TS 6.0, not 5.0. Further, PSEG is incorporating the STS language, as modified by TSTF-358, to replace SR 4.0.3

ATTACHMENT 1 LCR S02-02 LR-N02-0227 SALEM GENERATING STATION UNIT NOS. I AND 2 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM and the supporting Bases in their entirety. There are no substantive differences between the existing SR 4.0.3 and the corresponding STS requirements, only wording. Therefore, the evaluation and justification presented in TSTF-358 remain fully applicable.

PSEG is further proposing a minor editorial change from the TS Bases Control Program presented in STS paragraph 5.5.14.d, in order to enhance clarity.

3. REGULATORY ANALYSIS No Significant Hazards ConsiderationDetermination PSEG has reviewed the proposed No Significant Hazards Consideration determination published in the Federal Register as part of the CLIIP (Ref. 2) and the updated version in TSTF-358, Rev. 6 (Ref. 1). PSEG concludes that the proposed determination presented in NRC-approved TSTF-358, Rev. 6 is applicable to Salem Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10CFR50.91 (a).

Verification and Commitments As discussed in the Notice of Availability published in Federal Register 66FR49714 on September 28, 2001 for this TS improvement, plant-specific verifications were performed. PSEG will implement changes to TS Bases for SR 4.0.3 which state that use of the delay period established for SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of a missed surveillance.

The modification will also include changes to the Bases for SR 4.0.3 that provide details on how to implement the new requirements. These Bases changes provide guidance for surveillance frequencies that are not based on time intervals, but are based on specified unit conditions, operating situations or the requirements of regulations. In addition, the Bases changes state that PSEG is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations such as the impact on plant risk and accident analysis assumptions, unit conditions, planning, availability of personnel and time required to perform the surveillance.

The Bases also state the risk impact should be managed through the 10CFR50.65(a)(4) Maintenance Rule program, including associated NRC

ATTACHMENT 1 LCR S02-02 LR-N02-0227 SALEM GENERATING STATION UNIT NOS. I AND 2 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM Regulatory Guide 1.182, Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants. The Bases further state that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that a missed surveillance for an important component should be analyzed quantitatively. The results of the risk evaluation should determine the appropriate course of action.

Finally, the Bases state that all missed surveillance tests will be placed in the licensee's corrective action program. This submittal incorporates a Bases Control Program at PSEG Nuclear consistent with Section 5.5 of the STS.

4. ENVIRONMENTAL EVALUATION PSEG has reviewed the environmental evaluation included in the model safety evaluation from 66FR32400 dated June 14, 2001 and has concluded that the staff's findings presented in the evaluation are applicable to Salem and the evaluation is hereby incorporated by reference for this application.
5. REFERENCES
1. Industry/Technical Specification Task Force Standard Technical Specification Change Traveler, TSTF-358, Rev. 6; Missed Surveillance Requirements.
2. Federal Register 66FR32400, Notice of Opportunityto Comment on Model Safety Evaluation on TS Improvement to Modify Requirements Regarding Missed Surveillances Using CLIIP, dated June 14, 2001.
3. Federal Register 66FR49714, Notice of Availability of Model Application Concerning TS Improvement to Modify Requirements Regarding Missed Surveillances Using CLIIP, dated September 28, 2001.
4. Letter W. D. Beckner (NRC) to A. R. Pietrangelo (NEI) approving TSTF-358, Rev. 6, dated October 3, 2001,
5. NUREG-1431, Rev. 2, Standard Technical Specifications for Westinghouse Plants

ATTACHMENT 2 LCR S02-02 LR-N02-0227 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Salem Unit 1, Facility Operating License DPR-70, are affected by this change request:

Technical Specification Page 4.0.3 3/4 0-2a 6.17 (New) 6-31 (New)

Bases 4.0.3 B 3/4 0-6, B 3/4 0-7 The following Technical Specifications for Salem Unit 2, Facility Operating License DPR-75, are affected by this change request:

Technical Specification Page 4.0.3 3/4 0-2a 6.16 (New) 6-30 Bases 4.0.3 B 3/4 0-6, B 3/4 0-7

ATTACHMENT 2 LCR S02-02 LR-N02-0227 SALEM MARKED-UP TECHNICAL SPECIFICATION PAGES Insert A (Completely replaces existing 4.0.3)

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. 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 Actions 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 Actions must be entered.

APPLICABILMT SURVZZLLANCZ RZQU!ZXZXNTS 4.0.1 Surveillance Requirements shall be met during the OPMRATIONAL HOOKS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 Failure, to per a Surveillance Requirement within t/ e surveillance al. defined by Specification 4.0 constitute a failure t the OPIRABILITY requirma a Limiting Condition fac-o pe on. The time limits of the 9 requirements are appli e at the it is identified that veillanca Requirement hail *d

-socan performeX*

d.m The ACTION requiremo y be delayed for up to 24 s to permit the capltion of surveillance when the allowe5,diage time limits of the ACTý"IO irements are less than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -'urvuillance Requirements do not 4.0.4 Entry into an OPERATIONAL, MO02 or other specified condition shall not be made unless the Surveillance Requireame nt(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPEMATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASHE Code Class 1, 2 and 3 corponants shall be applicable as follows:

a. InservLce inspection of ASNZ Code Class 1, 2 and 3 components and inservLce testing of ASHE Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASMZ Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CYR SO Section E0.5Sa(g), except where specific written relief has been granted by the Coamission pursuant to 10 CYR 50, Section 5O.SSa(g)(6)(i).
b. Surveillance intervals specified in Section XX of the ASlI Seiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASN4 Seiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications, SAL3Xf- UNIT I 3/4 0-2a Amendment No. 131

SUVM ILLAZICEQ UQIREMENTS uUlnllUll l mu. -

aila. uilmi~n~liilBtUi..l.mUUlllllll llol n lU Bll ll $ ll l ml 4.0.1 SurveiLlance Requirements shall be met during the OPERATZONAL MODES other conditions specified for Individual LimLting Conditions for operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement @hall be perfoemed within the specified surveillance interval with a maximum allowable extension not to exceed 25 j4ercent of the mpezoc Led cnurov a interval.

surveillance interval fined by Specification 4.0.2, constitute a failure to meeot SOvPE ILITe requLrements for iting Condition for Operation. e time Limits of the erford irements arm applLcab t the tILe i*iSdentified that a Su ce Requirement has not niperformed.

ACTION goe nts are loes than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. sillance Requireemntu do not 4.0.4 Entry Into an OPERATIONAL NODE or other specified condition shall not be made unless the Surveillance Requirement(s) aseociated with~ the Limiting Condition for Operation have been perfoTmed within the stated surveillance interval oc as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for Inservice inspection and testing of ASME Code Class 1. 2 and 3 components shall be applicable as follows:

a. Inservice Inspection oa AM Code Class 1, 2 and 3 components and inservi ce testing of P.5H1 Code Class 1. 2 and 3 pumps and valves shall be performed in accordance with Section XT of the AIl4 Bailer and Pressure Vessel Code and applicable Addenda as required by 10 ClR 50, Section SO.SSa4q), except where specific written relief has been granted by the Comimsion pursuant to 10 Crh SO, Section SO.55a(g) (6) (1).
b. Surveillance intervals specified in Section XX of the ASH Bailoer and Pressure Vessel Code and applicable Addenda for the Lnservice inspection and testing activities required by the AS4Z Boalor and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

SALEM - UNIT 2 3/4 0-2a Amendent No. 110

ATTACHMENT 2 LCR S02-02 LR-N02-0227 Insert B (New TS 6.17 for Salem Unit 1 and TS 6.16 for Salem Unit 2) 6.17 (6.16) TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b. PSEG may make changes to the Bases without prior NRC approval provided the changes do not require either of the following:
1. A change in the TS incorporated in the License, or
2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
c. Proposed changes to the Bases that require either condition of Specification 6.17.b (6.16.b) above shall be reviewed and approved by the NRC prior to implementation.
d. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
e. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

ACHWCES'1PAfVE aCiirnS C. A detailed descriptiCri of the S*ip* ccutu* and processe involved and the. interface with other plant,

d. An wna~uatica of the change 4itdc mhm the prudicted relemamm of reimtieuabrials in lI Igid and gamm of flumnts ar4/or quantitY of lid4 want, that differ from Him previciumy predicted in the liuene appliatiam and meimets
e. An evaluatien of the change, W+/-dx shw the aqaected 2dmixi expome to inividual in the wirticted am and to the general pcpalation that. differ from Utin pmwiamsly efinsited. in the license a aid -vb'm*

dlmi thrs

f. A ccoparism of the predicted releiMN of radiOmCtive mearials, in liquid and pgams efflumnts and in molId waste, to the aobial releases for the period priw to %ba the change are to be made;
g. An etimte, of the cexmz to plait cpeatziq peraminul as a reslt of the diwnge aid
h. n= mitation of the fact that th wasgrevima and fourid accetable by th (S~n.
2. Sball baCm effetive .UPM riMAW and aCCIItarm bY tha SM.

6.1L a .0k,O'p I 0 %,.1Oweýi F.A A g 4

ý-* %'ý ý -ý %'

6.16.1 All safety-related electrical eqlipm* in the facility shall be qualified in acodmm with the pmwisicmu of: Division of uxtn FActazu Woud*im for EVmlustinq Dwvi I 1 11-11fhicaicina of Claw IR ElectIml khalpet in Cparting Fleatore (am liin);i , NL.TR.-0586 mziteda Staff PositIm en wx~l~~f~tm of Safety-Fleated Electrical FZidp~t," Iemomer 1979. CbW Of HIM dD~tu are &ttahd~

to Ova for ibdifiomtion of Licene No. DP-70 dated Octaber 24# 1980.

G.16.3 Cmlutmad mud iitable r~d" he'lI be available and naintained at a in,1 mn*a1 IIdI whotiic crbe the m Uw~auiita

~dUsed for all safety zulatad eliectrioml. eqdiw* in uffilm* detail to domot the degpe of o.m1iana with th EM GaideUZe or ME-OW6. Mzh r --

  • Wum be twdsetd aid mintaized acurzt as eqilpmt is rqe1aced futher tated, or otherisxie further qualified.

IS&rt '

SNMD - UmT 1 63 6-30 Awwwmt No. L-.1

ADMINISTRATIVE CONTROLS 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation.

6.14.2 Changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained as required by Specification 6 .10.3p. This documentation shall contain:

a) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and b) A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190, .10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

2. Shall become effective after review and acceptance by the SORC and the approval of the Plant Manager.
3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g. month/year] the change was implemented.

6.15 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS 6.15.1 Licensee initiated major changes to the radioactive waste system (liquid, gaseous and solid):

1. Shall be reported to the Commission in the UFSAR for the period in which the evaluation was reviewed by (SORC). The discussion of each change shall contain:
a. A summary of the evaluation that led td the determination that the change could be made in accordance with 10CFR50.59;
b. Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; SALEM - UNIT 2 6-29 mAendment No. 215

to ATTACHMENT 3 LCR S02-02 LR-N02-0227 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by PSEG in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Carl Berger at (856) 339-1432.

Regulatory Commitments Due datelevent PSEG will establish the Technical Specification Complete or implemented Bases for SR 4.0.3 as adopted with the with amendment applicable license amendment PSEG will establish a Technical Specification Complete or implemented Bases control program consistent with this with amendment submittal.

ATTACHMENT 4 LCR S02-02 LR-N02-0227 PROPOSED CHANGES TO TS BASES PAGES Insert C (Replacesexisting Bases for TS 4.0.3)

Surveillance 4.0.3 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 is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with TS 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.

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 4.0.3 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 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified frequencies for Surveillances is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational 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 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

ATTACHMENT 4 LCR S02-02 LR-N02-0227 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 CFR50.65(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 licensee's 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 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 Completions Times of the Required Actions for the applicable LCO begins 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 4.0.1.

APPL:CABIL:IýY BASES particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded = d that obtaine m the specified surveillance soecification 4.0.3 establish the failure to perform a Surveillance Requirement within the aled surveillance interval, defined by the provt.ions of SpecIf* Lon 4.0.2, as a condition that titutes a failure to meet the oPE TY requirements for a Limitin ndition for Operation.

Under the prov:wRons of this specification, sy s and components are assumet to be OPE when Surveillance RequireT s f have been atiesfactorily e t n time i al. inop a t ing it t lis r b e nothing HOwever, performs Lth the rpecifred r on to b r o n X wh n t e OP~~~~~

identified tha~ a vel anc ~htonot b pe2'rfreannoathete that the sreillanc e inta edad. Clt o the SeSurveill Requiremen Thint palloiatle age t iiithao t /c ACTIO requirements r ore licabe wh ith th requirementsof tO have perfot ed the e allowe wvaid illance interval, de fined o by the p roin;of Sm c fiitsa io Copl nd

.0., or . io lation w Operation of the that is OPERADILITY e ATrequit perf orm at ...

subnt t to a ot surveillac wionso s ficeatio Co4.0.2 isa v ti Suvif theqirmn wti outage allowable limits of tme thACONrqr ntaelsshn 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rasud i requiremedesoe to comply with Aherequirements eog.

Te c h n i c p c f c t o e u r m n s h r f r , a r p r a l v n surveillance Thwi hs rthin alowfbl rvsos includsons402Ian adequate i olatio time limit or pan t implementin 4t ACTIO retui sdee loted. Scomplete The pur pose S eillance R etha t vsh perfor the reuiremences of1ndrth s ation (afetysignifi cance it is eay foreain o of tin bywahe i to pecithe of a veilatnc copliieti sAbyrequire thesquired'surveillan pc. icthisrovis. as rvdsatm or before other is shu to aoplimiAnConrquirements lIfith flormeoaures remedial abe ompltionm be imt of Suvellne wouldactirndthathmapeclude ACTuIO nti tompletion thabecoeofaaplictabl Tcnic .atortal, t trqired t v*e a2sa con aquence of MODE changes imposed wt requ irementand foer ,

Iompleting Surveillance Requirements Tire applcable when an exception e to requ lrements of Specificat ton 4 is allow ed. Sthe If a surveillance is n completed within the 24-hour z vowance, the time ismite of the ACTION t cirements are a t.en applicable h a euepte on t S M UNI I 3/40-6Amendment No.131

APPLICASILITY BASES

= .z z ss *=== S

  • U
  • Sn *
  • S S--== Sm m = z n s s s w s s = = = = t within the 24-hour allowa and the Surveillance Requi s are not met, the time limits of t CTION requirements are ap iable at the time that th surveillance is t inated. If a surveillan eot is to be performed when certain cond no exist and the provisi of Specification 4.0.4 ar t hich those conditions wou /

applicab or entry into the mode achi dth time interval, w or it be the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all e or the owed outage time of the Lon statement, begins who e plant reaches the conditions necesseary terform the test.

ireruents do not have to b erformed on inoperable aq ant Surveillance because ACTION requirements dsfine a remedial measures that a y.

7 Howeve , theequipment Hinoperable Surveillance has beenRequLrteeitereda to have to be met OPERABLE to demon status.* ate that surveillances must be met before entry into an OPERATIONAL NODE or other purpose condition of operation specified in the Applicability statement. The of this specification is to ensure that system and component OPERASILITY requirements or parameter limits are met before entry into a MODE or condition facility.

for which these systems and components ensure safe operation of the to changes in OPERATIONAL MODES or other specified This provision applies conditions associated with plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance interval to Requirements must be performed within the specified surveillance Conditions for Operation are met during initial plant ensure that the Limiting startup or following a plant outage.

the provisions When a shutdown is required to comply with ACTION requirements, because this could delay placing the of Specification 4.0.4 do not apply facility in a lower MODE of operation.

the requirement that inservice inspection of S2ecification 4.0.5 establishes Code ASKE Code Class 1, 2, and 3 components and inservice testing of ASME a and valves shall be performed in accordance with Class 1, 2, and 3 pumps and Pressure periodically updated version of Section XI of the ASKM Boiler Vessel Cods and Addenda as required by 10 CPR 50.55a. These requirements apply except when relief has been provided in writing by the Commission.

for performing This specification includes a clarification of the frequencies and testing activities required by Section XI of the the inservice inspection ASKE Boiler and Pressure Vessel Code and applicable Addenda. This is provided to ensure consistency in surveillance intervals clarification and to remove any ambiguities relative throughout the Technical Specifications the required inservice inspection and to the frequencies for performing testing activities.

of under the terms of this specification, the more restrictive requirements over the ASKM Boiler and Pressure the Technical Specifications take precedence The requirements of Specification 4.0.4 Vessel Code and applicable Addenda.

MODE or to perform surveillance activities before entry into an OPERATIONAL B 3/4 0-7 Amendment No. 131 SALEM - UNIT I

APPL:CABIL:TY BASES particular survei.llance bei.ng performed is the verification of conformance with the Surve.L~lance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surve~illan~ce interval..I

.Specificationl 4.0.-3 a ablishes the failure erform a Surveillance Requirement within eallowed surveillan Winterval, defined by previsions of cification 4.0.2, a condition that const* as a failure to meet the ERABILITY r9%irme for a Limiting cond n, for Opera n Under th rovisions of thi a fication, sysntemsn a components assumed to be ERALE when Surveil co Requirements ha In Isatifa rCily p mrod within the speciLed me interval, waver, net in this ovizsion is to be con rued as implying th systems or ponents ire OPERABLE when they e found or known to inoperabl though still meeting the Surveillance equirements. This ci! ication so clarifies that the ACTION requir ants are applicabi. hen Survei.l nee Requirements have not been compl edwithin the allo survoillan Interval and that the t' limits the ACTION requir nts apply f the point in time it is iden Led that a surveil nce has no son performed and not at a time th the allowed surve lance Into 1 was exceeded. Complet of the urveillance Requir ant within a allowable outage time its of the ACTION requirearn A restores mpliance with the requir nt. of Specification .0.3. Howe r, this does not negate e fact that the failure to have per rmed the o cillance within the al e surveillance. interv defined the provi ons of Specification 4.0 , was a violation of OPt MT requi ants of a Limiting forA Ion for Operation th is

,sub t to en! cement action. Further he failure to perfo 6 veillane ithin the provisions o pecification 4.0.2 a violation of a Tchnica pecification reuren and is, therefore, reportable event under a requirements of qj10 CF 50.73(a)(2)(i){D) cause it is a condition pro ited by the plant's To nical Specificati If the allowable outag time limits of th CTION requirements are 1.eý t~han 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or a shutd n is required to ly with ACTION requirimt s, e.g.,

Specification 3. ,a 24-hour all nee is provided to permit delay in implementing ACTION requir tin. This provides an !ad at t--Ime limit to complete Su eillance Requir nts that have not been formed. The purpose of this owance is to it the completion of a rveillance before a shutd is required t comply with ACTION re emwants or before other rem ial measures w d be required that ma reclude completion of a surveillance. T basis for this allow e Includes consideratio or plant conditions, a ates planning, avail lity of personnel, the required t perform the urvaillance , and the afety significance of t delay in completi the required surve' &nce. This provision o provides a time limit r the completion o urveillance Requiremen ta eoeapial as consequence 'Of MOD changes imposed by AC rquirements and for completing Surveil, 0 Requirements that ar pplicable when an exception to the requirements Specification 4.0.4 i Iowed. if a surveillance is no completed wit the 24-hour allowanc he time limits of the ACTION SALEM - UNIT 2 8 3/4 0-6 Amendment No. 110

8PPL:CBA!:TY BASES within the 24-hour allow ce and the Surve1 anee Requirements not ,

the t~mo limits of t ACTIORJ requirem a are applicable the time t.-az tne su'rveillance is If a veillance test snaned.

is a performed wnen certain cond. one exist and t provisions of Spec Ication 4.0.4 are applicabl or entry into t mode at which tho conditions would te achiev . the time intero whether it be t 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance or -.e al ed outage time the action stat *begins when the pla reaches %-a onditions necess to perform the t.

Surveill Requirements do have to be performed inoperable equ~mern:

becaus he ACTION requir nns define the remedi measures that apply.

Howev r, the Surveilla Requirements have to met to demonstrate that nop b eupe an boon restored to RADIX status.

asal arqi that all. applicable surveillances must be mot before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The pur~csa of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MO0DE or condit-=n for which theme systems and components ensure safe operation of the facili.ty.

This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well an startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance intsrva. t ensure that the Limiting Conditions for Operation are met during initial p-n startup or following a plant outage.

When a shutdown is~requirmd to comply with ACTION requirements, the prcv~.sL:ns of Specification 4.0.4 do not apply because this could delay placing th'e facility in a lower MODE of operation.

Snpecificalion 4.0.5 establishes the requirement that inservice inspecticn z ASME Code Class 1, 2, and 3 components and inservice testing ot ASI4Z Ccde SALdEMo Class 1, NI

- B~insecfe 2 3 pumps and valves

2. and 3/4 shall 0-7 Api amends~ment be performed N. 110 with in accordanqo pt~ea peri~odically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CYR 50.55a. These requirements apply except when relief has been provided in writing by the Commissicn.

This specification includes a clarification of the frequencies for perfor-.in the inservice inspection and testing activities required by Section X1 :zf tn-e AS142 Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and to remove any ambiguiti~es realat;2:.e to the frequencies for performing the required inservice inspection and testing activities.

Under the terms of this specification, the more restrictive requirements =f the Technical Specifications take precedence over the ASME Boiler and Press.re Vessel Code and applicable Addenda. The requirements of Specification 4.:..

to perform surveillance activities before entry into an OPERATIONAL MODE o r SALEM - UNIT 2 B 3/4 0-7 Amendment No. 110

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