Text

Application for Amendment to License DPR-65 to Modify Technical Specifications Requirements for Missed Surveillances in Specification 4.0.3 & Modify Associated TS Bases
	ML022120456
Person / Time
Site:	Millstone
Issue date:	07/19/2002
From:	Price J; Dominion Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	B18608
	Download: ML022120456 (28)
	v • d • e

D)...iiOn Nlde ,,0.'1,itt,Inc. D o m in io n

p. JUL q92C'0?

Docket No. 50-336 B18608 RE: 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIJP)

Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) proposes to amend Operating License No. DPR-65 by incorporating the proposed changes into the Millstone Unit No. 2 Technical Specifications. The proposed amendment would modify the Technical Specification requirements for missed surveillances in Specification 4.0.3 as well as modify the associated Technical Specification Bases. The changes are consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF), Standard Technical Specification (STS) Change TSTF-358, Revision 6. The availability of this Technical Specification improvement was published in the Federal Register on September 28, 2001, (Federal Register Notice 66FR 49714) as part of the Consolidated Line Item Improvement Process (CLIIP). provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verification. Attachment 2 provides the existing Technical Specification pages, including Bases pages, marked up to show the proposed changes. Attachment 3 provides the retyped pages. Attachment 4 provides a summary of the regulatory commitments made in this submittal.

The proposed amendment request does not involve a significant hazards consideration pursuant to the provisions of 10 CFR 50.92 (Attachment 1). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment (Attachment 1).

The Site Operations Review Committee and Nuclear Safety Assessment Board have reviewed and concurred with the determinations.

U.S. Nuclear Regulatory Commission B18608/Page 2 In a letter dated November 8, 2001,(1) DNC submitted a license amendment request to incorporate a Technical Specification Bases control program within the Millstone Unit No. 2 Technical Specifications, with a request for approval by November 7, 2002. We would like to implement the amendment related to the missed surveillance concurrent with or after the implementation of the amendment related to the Bases control program. Therefore, we request issuance of this amendment by November 30, 2002, with the amendment to be implemented within 90 days of issuance.

In accordance with 10 CFR 50.91(b), a copy of this License Amendment Request is being provided to the State of Connecticut.

The regulatory commitments contained in this letter are located in Attachment 4.

If you should have any questions regarding this submittal, please contact Mr. Ravi Joshi at (860) 440-2080.

Very truly yours, DOMINION NUCLEAR CONNECTICUT, INC.

J.Alan[P ,

Site Vik&e.resident - Millstone Subscribed and sworn to before me this q" day of 7U) U 2002 Notary Public Date Commission Expires: __________,__

MVclMMPI LEW l cc: See next page

j. Alan Price letter to the U.S. Nuclear Regulatory Commission, "Millstone Nuclear Power J1 Station, Unit Nos. 1, 2 and 3, Technical Specification Change Request, Administrative and Editorial Changes to Unit Nos. 1, 2 and 3 Technical Specifications," dated November 8, 2001.

U.S. Nuclear Regulatory Commission B18608/Page 3 Attachments (4) cc: H. J. Miller, Region I Administrator R. B. Ennis, NRC Senior Project Manager, Millstone Unit No. 2 NRC Senior Resident Inspector, Millstone Unit No. 2 Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Docket No. 50-336 B18608 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

Discussion of the Proposed Changes and Assessment

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 1 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

Discussion of the Proposed Changes and Assessment

1. INTRODUCTION The proposed amendment would revise the Millstone Unit No. 2 Technical Specification 4.0.3 requirements for missed surveillances consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF), Standard Technical Specification (STS) Change TSTF-358, Revision 6. The proposed changes are being submitted in conjunction with the Consolidated Line Item Improvement Process (CLIIP).

2. DESCRIPTION OF THE PROPOSED CHANGE The proposed amendment would revise Technical Specification requirements for missed surveillances in Specifications 4.0.1 and 4.0.3. Dominion Nuclear Connecticut, Inc. (DNC) proposes to make the following three (3) specific changes to accommodate the changes addressed by the CLIIP.

"* Convert Specifications 4.0.1 and 4.0.3 from current Millstone Unit No. 2 Technical Specifications format to Improved Standard Technical Specification format (i.e., NUREG-1432).

"* Incorporate the changes proposed by TSTF-358, Revision 6 (CLIIP).

"* Incorporate a Bases Control Program into Section 6.0, Administrative Controls.

In a letter dated November 8, 2001,(1) DNC submitted a license amendment request to incorporate a Technical Specification Bases Control Program within the Millstone Unit No. 2 Technical Specifications.

3. ASSESSMENT 3.1 Optional Changes and Variations Current Millstone Unit No. 2 Technical Specifications allow a delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform a missed surveillance prior to meeting the associated ACTION requirements. The proposed changes, which are based on industry and NRC approved TSTF-358, Revision 6, would modify this delay period to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the specified surveillance interval, whichever is greater. A risk evaluation would be performed for any missed surveillance delayed greater (1) J. Alan Price letter to the U.S. Nuclear Regulatory Commission, "Millstone Nuclear Power Station, Unit Nos. 1, 2 and 3, Technical Specification Change Request, Administrative and Editorial Changes to Unit Nos. 1, 2 and 3 Technical Specifications," dated November 8, 2001.

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 2 than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . A missed surveillance requiring a Mode change or other change in plant conditions would be performed at the first reasonable opportunity. The benefit of this proposed amendment request would be reduction of the need to apply for regulatory relief for a missed surveillance and the associated need to subject the unit to otherwise unnecessary plant transients or shutdowns. The availability of this Technical Specification improvement was published in the Federal Register on September 28, 2001, (Federal Register Notice 66 FR 449714) as part of the CLIIP.

Due to the vintage of the Millstone Unit No. 2 Technical Specifications, incorporation of the changes in the CLIIP will entail three (3) areas of change.

First, DNC proposes to modify the wording of the current Specifications 4.0.1 and 4.0.3 to be consistent with NUREG-1432, Revision 2. These changes are necessary in order to make the current Technical Specifications compatible with the proposed changes of TSTF-358. Second, Specification 4.0.3 and associated Bases will be modified in accordance with the CLIIP. Finally, since DNC has not fully implemented the Improved Standard Technical Specifications, DNC proposes to incorporate a Bases Control Program in Section 6.0 of the Technical Specifications as follows. In a letter dated November 8, 2001, DNC submitted a license amendment request to incorporate a Technical Specification Bases Control Program within the Millstone Unit No. 2 Technical Specifications. The amendment request is currently under NRC review.

3.1 Safety Evaluation Conversion to Improved Technical Specification Format Specifications 4.0.1 and 4.0.3 are being modified to be consistent with NUREG-1432, Revision 2, Surveillance Requirements 3.0.1 and 3.0.3. These changes are necessary to make the current Millstone Unit No. 2 Technical Specifications compatible with the proposed changes of TSTF-358, Revision 6.

These changes are only administrative in nature.

Incorporation of TSTF-358, Revision 6 DNC has reviewed the proposed NRC safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001, as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-358. DNC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Millstone Unit No. 2 and justify this amendment for incorporation of the changes to the Millstone Unit No. 2 Technical Specifications.

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 3 Incorporation of Bases Control Program DNC will be implementing the Bases Control Program for Millstone Unit No. 2 once the NRC approves our license amendment request dated November 8, 2001. This change is only administrative in nature.

4. REGULATORY ANALYSIS 4.1 No Significant Hazards Consideration In accordance with 10 CFR 50.92, DNC has reviewed the proposed changes and has concluded that they do not involve a Significant Hazards Consideration (SHC). The following is provided in support of this conclusion.

Conversion to Improved Technical Specification Format The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change involves rewording of the existing Technical Specifications to be consistent with NUREG-1432, Revision 2. These modifications involve no technical changes to the existing Technical Specifications. As such, these changes are administrative in nature and do not affect initiators of analyzed events or assumed mitigation of accident or transient events. Therefore, these changes will not increase the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change involves rewording of the existing Technical Specifications to be consistent with NUREG-1432, Revision 2. The change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of safety.

The proposed change involves rewording of the existing Technical Specifications to be consistent with NUREG-1432, Revision 2. The changes are administrative in nature and will not involve any technical changes. The changes will not reduce a margin of safety because they

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 4 have no impact on any safety analysis assumptions. Also, since these changes are administrative in nature, no question of safety is involved.

Therefore, there will be no reduction in a margin of safety.

Incorporation of TSTF-358, Revision 6 DNC has reviewed the no significant hazards consideration determination published in the Federal Register as part of the CLIIP. DNC has concluded that the determination presented in the Federal Register notice is applicable to Millstone Unit No. 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Incorporation of Bases Control Proqram In a letter dated November 8, 2001, DNC submitted a license amendment request to incorporate a Bases Control Program within the Millstone Unit No. 2 Technical Specifications. Pursuant to the provisions of 10 CFR 50.92, it was concluded that the proposed changes contained in the amendment request did not involve a Significant Hazards Considerations.

4.2 Verification and Commitments As discussed in the Notice of Availability published in the Federal Register on September 28, 2001, for this Technical Specification improvements, plant specific verifications were performed as follows: DNC will implement changes to Technical Specification Bases for Specification 4.0.3, which state that the use of the delay period established for Specification 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 Specification 4.0.3 that provide details on how to implement the new requirements. The Bases changes 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 state that DNC 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, consideration of unit conditions, planning availability of personnel, and time required to perform the surveillance. The Bases 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 state that 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

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 5 component should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the course of action. In addition, the Bases state that all missed surveillance tests will be placed in the licensee's corrective action program. DNC will establish the Technical Specification Bases for Specification 4.0.3 as adopted with this license amendment (see Attachment 4). Finally, DNC will implement a Bases Control Program once NRC approves our license amendment request dated November 8, 2001.

5. ENVIRONMENTAL EVALUATION Conversions to Improved Technical Specification Format DNC has evaluated the proposed changes against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.22. DNC has determined that the proposed changes meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and as such, has determined that no irreversible consequences exists in accordance with 10 CFR 50.92(b). This determination is based on the fact that the changes are being proposed as an amendment to a license issued pursuant to 10 CFR 50 to revise Specifications 4.0.1 and 4.0.3 to be consistent with NUREG-1432, Revision 2 and that the amendment request meets the following specific criteria:

(i) The propose change involves no significant hazards consideration.

As demonstrated above, the proposed changes do not involve a significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released off site.

The proposed changes will revise Specifications 4.0.1 and 4.0.3 to be consistent with NUREG-1432, Revision 2. The proposed changes will not change the design basis of the plant. The proposed changes will not result in an increase in power level, will not increase the production of radioactive waste and byproducts, and will not alter the flowpath or method of disposal of radioactive waste or byproducts. Therefore, the proposed changes will not increase the types and amounts of effluents that may be released off site.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes will not result in changes in the configuration of the facility. The proposed changes will only revise specifications 4.0.1 and 4.0.3 to be consistent with NUREG-1432, Revision 2. There will be no changes in the level of controls or methodology used for processing radioactive effluents or the handling of solid radioactive waste. There will be no change to the normal radiation levels within the plant. Therefore, there will be no increase in

U.S. Nuclear Regulatory Commission B18608/Attachment 1/Page 6 individual or cumulative occupational radiation exposure resulting from the proposed changes.

Incorporation of TSTF-358, Revision 6 DNC has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001, as part of the CLIIP. DNC has concluded that the staffs findings presented in that evaluation are applicable to Millstone Unit No. 2 and the evaluation is hereby incorporated by reference for this application.

Incorporation of Bases Control Program In a letter dated November 8, 2001, DNC submitted a license amendment request to incorporate a Bases Control Program within the Millstone Unit No. 2 Technical Specifications. The amendment request concluded that the proposed request met the eligibility criteria for categorical exclusion set fourth in 10 CFR 51.22(c)(9). Thus, pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement needs to be prepared in connection with the issuance of that amendment.

Docket No. 50-336 B18608 Attachment 2 Millstone Nuclear Power Station, Unit No. 2 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

Marked Up Pages

U.S. Nuclear Regulatory Commission B 18608/Attachment 2/Page 1 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

Marked Up Pages Technical Specification Affected Pages with Section Number Section Title Amendment Number Specification 4.0.1 and Applicability - Surveillance Requirements 3/4 0-2 Amend. No. 230 4.0.3 Base Specification 4.0.1 Applicability - Surveillance Requirements B 3/4 0-5a Amend. No. 230 Base Specification 4.0.3 Applicability - Surveillance Requirements B 3/4 0-6 April 12, 1991 NOTE TO THE REVIEWER:

"* The Inserts are made to incorporate standard improved technical specification language into the current Millstone No. 2 Technical Specifications.

"* Italicized formatting is used to identify CLIIP - related changes.

APPLICABILITY March 11, 1999 LIMITING CONDITION FOR OPERATION (Continued)

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This specification is not applicable in MODES 5 or 6.

3.0.6 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.

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be appl4iab-l-e during the OPERATIONAL MODES 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 time interval with a maximum allowable extension not to exceed 25%

of the surveillance time interval. *-*-ýwm y IpJIET8 4.0.3 Fiu"1f -t= a Sur..illancct l f-em-nt within" the allowed F*,'*'s1llanc interal, 1defined b3 SpIecir.Cation 4.0n2, vhall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition f Operation. The time limits of the ACTION requirements are applicable at thee time it is identified that a Surveillance Requirement has not been performed.

The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the ompletion of the surveillance when the allowable outage time limits of the CTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Surveillance Requirements do not ave to be performed on inoperable equipmen 4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(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 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 of ASME Code Class 1, 2 and 3 components and inservice testing ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a.

MILLSTONE - UNIT 2 3/4 0-2 Amendment No. 97, 79, J*J, I, 230,

INSERT 'A' to page 3/4 0-2 (Specification 4.0.1)

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 Limiting Condition for Operation. Failure to perform a surveillance within the specified surveillance interval, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

INSERT 'B' to page 3/4 0-2 (Specification 4.0.3)

If it is discovered that a surveillance was not performed within its specified surveillance interval, then the compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is <<CLIIP>>greater. This delay period is permitted to allow performance of the surveillance. <<CLIIP>>A risk evaluation shall be performed for any surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the surveillance is not performed within the delay period, the Limiting Condition for Operation 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 Limiting Condition for Operation must immediately be declared not met, and the applicable Condition(s) must be entered.

BASES (Con't) March 11, 1999 BASES (Con't) March 11, 1999 Specification 4.0.1 through 4.0.5 establish the general requirements applic able to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, IOCFR50.36(c)(3):

"Surveillance requirements are requirements relating to test, cali bration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirements. The purpose of this specification is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are within

"_'specified limits to ensure safe operation of the facility when the plant is in arr a MODE or other specified condition for whJ;h the associated Limiting "Conditions tor Operation are applicable.*"Yurveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Specification 4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g.,

transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through MILLSTONE - UNIT 2 B 3/40O-5a Amendment No. 230

INSERT 'C' to page B 3/4 0-5a (Specification 4.0.1)

Failure to meet a surveillance within the specified surveillance interval, in accordance with Specification 4.0.2, constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE, when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

INSERT 'D' to page B 3/4 0-5a (Specification 4.0.1)

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given Surveillance Requirement. In this case, the unplanned event may be credited as fulfilling the performance of the Surveillance Requirement. This allowance includes those Surveillance Requirements whose performance is normally precluded in a given MODE or other specified condition.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with Specification 4.0.2 prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2.

Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressure > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE.

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

April 12, 1991 3/4.0 APPLICABILITY BASES (Con't) surveillance activities is not significantly degraded beyond that obtained from __the

_ specified surveillance interval.

_ _ 2eq v ,- l,)jar r \ [

Specification 4.0.3 establishes the failure to perform a Surveillance Require ment within the allowed surveillance interval, defined by the provisions Specification 4.0.2, as a condition that constitutes a failure to meet of OPERABILITY requirements for a Limiting Condition for Operation. Under the the provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed the allowed surveillance interval and that the time limits of the ACTION within requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3. However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation.

If the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown is required to comply with ACTION requirements, e.g., Specification 3.0.3, a 24-hour allowance is provided to permit in implementing the ACTION requirements. This provides an adequate a delay time limit to complete Surveillance Requirements that have not been performed.

The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of lance. The basis for this allowance includes consideration for planta surveil condi tions, adequate planning, availability of personnel, the time required perform the surveillance, and the safety significance of the delay to in complet ing the required surveillance. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time that the surveillance is terminated.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that However, the Surveillance Requirements have to be-met to demonstrate apply.

that i l ument has been restored to OPERABLE status.

MILLSTONE - UNIT 2 B 3/4 0-6

INSERT 'E' to page B 3/4 0-6 (Specification 4.0.3)

Specification 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 surveillance interval. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is <<CLIIP Change>> less greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval 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 Action requirements or other remedial measures that might preclude completion of the Surveillances.

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 results of any particular Surveillance being performed is the verification of conformance with the requirements. <<CLIIP>>--Whep-a SurveiIlanceith a lan timee ntervalc, but upon 6pccificd unit iitnteal based onsurieillaanc conditonra or operational s citfatien, it ditons, oeret to have bins performcnd Wh tpecified, Specification 4.0.3 allowf the full delay period of 21 hourS to pcrform the 8ue0laREee7 Specification 4.0.3 also provides a time limit fora completion of Suthepeoances that applicable as a enebecom of MOE conseqUeqne imposed by Rcquired Actions.

cchangee aCLu IP Change>>> When a Surveillance with a sureillance interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations, (e.g., prior to entering MODE I 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, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 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 surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. <<<CLIIP Change>>> While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval is provided to perform 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 Surveillance will be placed in the licensee's Corrective Acton 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 entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins 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 entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the applicable ACTIONS, restores compliance with Specification 4.0.1.

Docket No. 50-336 B18608 Attachment 3 Millstone Nuclear Power Station, Unit No. 2 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

Retyped Pages

APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued)

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This specification is not applicable in MODES 5 or 6.

3.0.6 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.

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

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 Limiting Condition for Operation.

Failure to perform a surveillance within the specified surveillance interval, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25%

of the surveillance time interval.

4.0.3 If it is discovered that a surveillance was not performed within its specified surveillance interval, then the compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the surveillance is not performed within the delayed period, the Limiting Condition for Operation 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 Limiting Condition of Operation must immediately be declared not met, and the applicable Condition(s) must be entered.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(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 OPERATIONAL MODES as required to comply with ACTION requirements.

MILLSTONE - UNIT 2 3/4 0-2 Amendment No. 97, 70, 791, W*7, 0830

APPLICABILITY LIMITING CONDITION FOR OPERATION 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 of ASME Code Class 1, 2 and 3 components and inservice testing ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a.

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

ASME Boiler and Pressure Vessel Code and applicable Required frequencies for Addenda terminology for performing inservice inservice inspection and inspection and testing testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

c. The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities.

d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.

e. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specifica tion.

MILLSTONE - UNIT 2 3/4 0-3 Amendment No. 97, 70, 191, M*,

0830 770,

BASES (Con't)

Specification 4.0.1 through 4.0.5 establish the general requirements applic able to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10CFR50.36(c)(3):

"Surveillance requirements are requirements relating to test, cali bration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirements. The purpose of this specification is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable. Failure to meet a surveillance within the specified surveillance interval, in accordance with Specification 4.0.2, constitutes a failure to meet an Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE, when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given Surveillance Requirement. In this case, the unplanned event may be credited as fulfilling the performance of the Surveillance Requirement. This allowance includes those Surveillance Requirements whose perforamnce is normally precluded in a given MODE or other specified condition.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. Surveillance have to be met and performed in accordance with Specification 4.0.2 prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2. Post maintenance testing may not be MILLSTONE - UNIT 2 B 3/4 0-5a Amendment No. 770, 0831

BASES (Con't) possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressure > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure.

Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE. This allows operations to reach the specified pressure to complete the necessary post maintenance testing.

Specification 4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g.,

transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any 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 beyond that obtained from the specified surveillance interval.

Specification 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 surveillance interval. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval was not met.

This delay period provides adequate time to complete Surveillance that have been missed. This delay period permits the completion of a Surveillance before complying with Action requirements or other remedial measures that might preclude completion of the Surveillances.

MILLSTONE - UNIT 2 B 3/40O-5b Amendment No. 77, 0831

BASES (Con't)

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 results of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a surveillance interval based not on time intervals, but upon unit conditions, operating situations, or requirements of regulations, (e.g., prior to entering MODE I 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, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 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 surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval is provided to perform 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 on 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 Surveillance 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 entry into the ACTION requirements for the applicable Limiting Condition for Operation begins 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 entry into the ACTION requirements for the applicable Limiting Condition for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the applicable ACTIONS, restores compliance with Specification 4.0.1.

MILLSTONE - UNIT 2 B 3/4 0-6 Amendment No.

0831

Docket No. 50-336 B18608 Attachment 4 Millstone Nuclear Power Station, Unit No. 2 License Basis Document Change Request 2-7-02 Missed Surveillances Using Consolidated Line Item Improvement Process (CLIIP)

List of Regulatory Commitments

U.S. Regulatory Commission B 18608/Attachment 4/Page 1 List of Regulatory Commitments The following table identifies action committed to by DNC in this document.

Number Commitment Due B18608-01 DNC will establish the Technical Specification To be implemented Bases for Specification 4.0.3 as adopted with with amendment.

the applicable license amendment.

ML022120456

Text

Navigation menu

Search