LIC-02-0066, License Amendment Request Re Technical Specification Change Regarding Missed Surveillance and Adoption of a Technical Specification Bases Control Program for Fort Calhoun Unit 1

License Amendment Request Re Technical Specification Change Regarding Missed Surveillance and Adoption of a Technical Specification Bases Control Program for Fort Calhoun Unit 1

ML022130581
Person / Time
Site:	Fort Calhoun
Issue date:	07/22/2002
From:	Ridenoure R Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-02-0066
Download: ML022130581 (28)

Text

'PMn Ornaha Public Power DsWC 444 South 16th Street Mall Omaha NE 68102-2247 July 22, 2002 LIC-02-0066 U. S. Nuclear Regulatory Commission ATTN.: Document Control Desk Washington, DC 20555

SUBJECT:

1.

Docket No. 50-285

2.

Improved Standard Technical Specification (ITS) for Combustion Engineering Plants, NUREG-1432, Revision 2

3.

Technical Specification Task Force Change Traveler TSTF-358, Revision 6

4.

Federal Register Notice dated September 28, 2001, Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process, Volume 66, No. 189 Fort Calhoun Station Unit No. 1 License Amendment Request, "Technical Specification Change Regarding Missed Surveillance and Adoption of a Technical Specification Bases Control Program" Pursuant to 10 CFR 50.90, Omaha Public Power District (OPPD) hereby transmits an application for amendment to the Fort Calhoun Station Unit 1 (FCS) Operating License. Attachment 1 provides the No Significant Hazards Evaluation and the technical bases for this requested change to the Technical Specifications (TS). Attachments 2 and 3 contain marked-up and clean-typed Technical Specification pages reflecting the requested Technical Specification and Basis changes.

The proposed amendment deletes TS requirements for missed Surveillances from TS 3.0.4 and adds TS 3.0.5 for missed Surveillances consistent with References 2 and 3.

This proposed amendment also adds a TS requirement for a Bases Control Program consistent with that presented in Section 5.5 of Reference 2 per the guidance of Reference 4. Appropriate TS Bases changes are also provided in accordance with Reference 4.

OPPD requests approval of the proposed amendment by January 15, 2003. Once approved, the amendment shall be implemented within 120 days.

Y\\ý Employment with Equal Opportunity 4171

U. S. Nuclear Regulatory Commission LIC-02-0066 Page 2 I declare under penalty of perjury that the foregoing is true and correct. (Executed on July 22, 2002)

If you have any questions or require additional information, please contact Dr. R. L. Jaworski at (402) 533-6833.

Sincerely, ivisi M

ager Nuci Op rations RTTRB/trb Attachments:

1. Fort Calhoun Station's Evaluation

2. Markup of Technical Specification Pages

3. Clean-Typed Technical Specification Pages c:

E. W. Merschoff, NRC Regional Administrator, Region IV A. B. Wang, NRC Project Manager J. G. Kramer, NRC Senior Resident Inspector Division Administrator - Public Health Assurance, State of Nebraska Winston & Strawn

LIC-02-0066 Page 1 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

OF PROPOSED AMENDMENT

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

LIC-02-0066 Page 2 Fort Calhoun Station's Evaluation For Amendment of Operating License

1.0 DESCRIPTION

The Omaha Public Power District (OPPD) proposes this amendment to the Fort Calhoun Station Unit 1 (FCS) Operating License to delete Technical Specification (TS) requirements for missed Surveillances from TS 3.0.4 and add TS 3.0.5 for missed Surveillances consistent with References 5.2 and 5.3. This proposed amendment also adds a TS requirement for a Bases Control Program consistent with that presented in Section 5.5 of Reference 5.2 per the guidance of Reference 5.4.

The following changes are proposed:

(1)

Change TS 3.0.4 to delete the following:

"The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

(2)

Add new TS 3.0.5 to read the following:

"If it is discovered that a Surveillance was not performed within its specified surveillance

interval, then compliance with the requirement to declare the OPERABILITY requirements for the Limiting Condition for Operation 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 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 <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 OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered."

LIC-02-0066 Page 3 (3)

Correct the last sentence of TS 5.19 to read the following:

"The provisions of Specifications 3.0.4 and 3.0.5 are applicable to the Containment Leakage Rate Testing Program."

(4)

Add new TS 5.20 to read the following:

"5.20 Technical Specifications (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.

Licensees may make changes to 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 USAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the USAR.

d.

Proposed changes that meet the criteria of 5.20.b above shall be reviewed and approved by the NRC prior to implementation. 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)."

These changes are consistent with the guidance of Reference 5.2.

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

LIC-02-0066 Page 4

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation OPPD has reviewed the safety evaluation dated June 14, 2001, as well as the Notice of Availability dated 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. OPPD has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to FCS and justify this amendment for the incorporation of the changes to the FCS TS.

TSTF-358 provides guidance on changing TSs that currently has a requirement similar to Improved Technical Specification (ITS) Surveillance Requirement (SR) 3.0.3 contained in Reference 5.2. ITS SR 3.0.3 provides 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 less to perform a missed Surveillance. It should be noted that OPPD has not yet implemented the requirements of ITS SR 3.0.3 at FCS. The changes to incorporate ITS SR 3.0.3 into the FCS TS and the addition of a TS Bases Control Program are evaluated below in Section 2.2 of this submittal separately from those changes evaluated in TSTF-358.

2.2 Optional Changes and Variations OPPD is not proposing any variations or deviations from the TS changes described in the fully modified TSTF-358 Revision 5 or the NRC staffs model safety evaluation dated June 14, 2001. However, by accepting the TS changes described in the fully modified TSTF-358 Revision 5, OPPD must modify FCS's current Specification 3.0.4 and add Specification 3.0.5 to incorporate elements of ITS SR 3.0.3 as discussed above.

By incorporating this change, other minor editorial changes are required. The adoption of ITS SR 3.0.3 wording would be essentially verbatim with the exception of the terms "Conditions," "Frequency," "Completion Times, "FSAR," and "Required Actions" used in ITS SR 3.0.3 would be changed to the corresponding terms as used in the current FCS TS. Also, TS 5.19 requires modification to ensure proper referencing of the new TS 3.0.5.

The proposed changes to modify Specification 3.0.4 and add Specification 3.0.5 to incorporate ITS SR 3.0.3 wording (as modified by NRC approved TSTF-358, Revision 5), as well as editorial changes in term usage, and the addition of the Technical Specification Bases Control Program are not considered a significant variation or deviation from the intent of the TSTF-358. Furthermore, the changes to incorporate ITS SR 3.0.3 into the FCS TS as Specification 3.0.5 and the addition of a TS Bases Control Program are evaluated below.

LIC-02-0066 Page 5 Incorporation of ITS SR 3.0.3 FCS TS 3.0.4 allows a delay of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a missed surveillance if the Required Action to be entered provides a Completion Time of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In Reference 5.2, SR 3.0.3 allows, at the time it is discovered that the Surveillance has not been performed, delaying the requirement to declare the equipment inoperable (Limiting Condition for Operation (LCO) not met) for 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 Surveillance frequency (whichever is less) regardless whether the Completion Times of the Actions are 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less. This is based on NRC Generic Letter 87-09, which states, "It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed.

The vast majority of surveillances demonstrate that systems or components are in fact operable. When a Surveillance is missed it is primarily a question of operability that has not been verified by the performance of the required surveillance."

Based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance and the safety significance of the delay in completing the Surveillance, the NRC concluded in Generic Letter 87-09 that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time limit for completing a missed Surveillance when the allowable outage time of the ACTIONS are less than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit or a shutdown is required to comply with ACTIONS.

Since 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> has been determined to be an acceptable time limit for completing the Surveillance, this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> deferral should apply to all systems or components, regardless of whether or not the associated allowable outage time is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less.

Shorter allowable outage times are generally provided for more safety significant Actions.

Therefore, if a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay can be safely applied to an Action with a short (e.g., 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) allowable outage time, there is less safety significance when a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay is applied to an Action with a long (e.g., 7 day) allowable outage time. Furthermore, consistent application of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay, regardless of allowable outage time, is critical to eliminating potential confusion and misapplication, e.g., Actions that have more than one allowable outage time. The confusion associated with the application of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> deferral to the allowable outage times of this example's Actions illustrates the potential for misapplication throughout the Technical Specifications. In addition, the limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not applicable if the specified Frequency is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The second and third paragraphs of Specification 3.0.5 are being added to clearly state the actions to take if the Surveillance is not performed within the delay period or the surveillance fails when performed. This clarification will help avoid confusion as to when the Completion Time(s) of the Required Action(s) begin in various situations. This change is less restrictive since it allows a grace period to perform a missed surveillance before entering the required actions regardless of the completion time. This change is consistent with Reference 5.2.

LIC-02-0066 Page 6 Addition of TS Bases Control Program A new section has been added to Section 5.0 Administrative Controls. Reference 5.4 requires licensees to include requirements for a TS Bases Control Program in order to adopt the allowances contained in TSTF-358. Adoption of this program will assure the continuing accuracy and adequacy of the Bases after the amendment is granted. This new administrative requirement has been included (Specification 5.20) which requires OPPD to develop and adopt a program which will perform this function. This represents an additional requirement for plant operation.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination OPPD has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. OPPD has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to FCS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

OPPD has also evaluated whether or not a significant hazards consideration is involved with the proposed change to incorporate ITS SR 3.0.3 into the FCS TS as Specification 3.0.5 and the addition of a TS Bases Control Program by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

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

Response: No.

The proposed change to incorporate Improved Standard Technical Specification (ITS) SR 3.0.3 relaxes the time allowed to perform a missed Surveillance. The time between Surveillances is not an initiator to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be OPERABLE and capable of performing the accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change to provide a Technical Specification (TS) Bases Control Program presents more stringent requirements than previously existed in the

LIC-02-0066 Page 7 Technical Specifications.

These more stringent requirements do not result in operation that will increase the probability of initiating an analyzed event. If anything the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive changes. The changes do not alter assumptions relative to mitigation of an accident or transient event. The more restrictive requirements continue to ensure process variables, structures, systems, and components are maintained consistent with the safety analyses and licensing basis. Therefore, the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No.

The proposed change to incorporate ITS SR 3.0.3 does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change to provide a TS Bases Control Program presents more stringent requirements than previously existed in the Technical Specifications.

The changes do not alter the plant configuration (no new or different type of equipment will be installed) or make changes in the methods governing normal plant operation. The changes do impose different requirements. However, these changes are consistent with the assumptions in the safety analyses and licensing basis. Therefore, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

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

Response: No.

The relaxed time allowed to perform a missed Surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any Surveillance is verification that the inoperable Limiting Condition for Operation LCO is met. Failure to perform a Surveillance within the prescribed Frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform a missed Surveillance on the

LIC-02-0066 Page 8 margin of safety is the extension of the time until inoperable equipment is discovered to be inoperable by the missed Surveillance. However, given the rare occurrence of inoperable equipment, and the rare occurrence of a missed Surveillance, a missed Surveillance on inoperable equipment would be very unlikely. This must be balanced against the real risk of manipulating the plant equipment or condition to perform the missed Surveillance. In addition, parallel trains and alternate equipment are typically available to perform the safety function of the equipment not tested. Thus, there is confidence that the equipment can perform its assumed safety function. Therefore, this change does not involve a significant reduction in a margin of safety.

The proposed change to provide a TS Bases Control Program presents more stringent requirements than previously existed in the Technical Specifications.

Adding more restrictive requirements either increases or has no impact on the margin of safety. The changes, by definition, provide additional restrictions to enhance plant safety.

The changes maintain requirements within the safety analyses and licensing basis.

As such, no question of safety is involved.

Therefore, the changes do not involve a significant reduction in a margin of safety.

Based on the above, Omaha Public Power District concludes that the proposed amendment to incorporate ITS SR 3.0.3 into the FCS TS as Specification 3.0.5 and add a TS Bases Control Program presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

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

OPPD has established TS Bases for Specification 3.0.5 which state that use of the delay period established by Specification 3.0.5 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.

The modification will also include changes to the Bases for Specification 3.0.5 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 OPPD is expected to perform a missed surveillance

LIC-02-0066 Page 9 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 the 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 missed surveillances for important components should be analyzed quantitatively.

The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the corrective action program. Finally, a new administrative control TS is proposed to be added to the TS to create a TS Bases Control Program. The new administrative control TS proposed is consistent with the TS Bases Control Program requirement as described in Section 5.5 of the Reference 5.2.

4.0 ENVIRONMENTAL CONSIDERATION

OPPD has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001 as part of the CLIIP. OPPD has concluded that the staffs findings presented in that evaluation are applicable to FCS and the evaluation is hereby incorporated by reference for this application.

Additionally, based on the above considerations, the proposed changes to incorporate ITS SR 3.0.3 into the FCS TS as Specification 3.0.5, correct TS 5.19 to properly reference the new TS 3.0.5, and to add a TS Bases Control Program do not involve and will not result in a condition which significantly alters the impact of Fort Calhoun Station on the environment. Thus, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR Part 51.22(c)(9), and, pursuant to 10 CFR Part 51.22(b), no environmental assessment need be prepared.

5.0 REFERENCES

5.1 Docket No. 50-285 5.2 Improved Standard Technical Specification (ITS) for Combustion Engineering Plants, NUREG--1432, Revision 2 5.3 Technical Specification Task Force Change Traveler TSTF-358, Revision 6 5.4 Federal Register Notice dated September 28, 2001, Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process, Volume 66, No. 189

LIC-02-0066 Page 1 ATTACHMENT 2 Markup of Technical Specification Pages

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.0.1 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.

3.0.2 The surveillance intervals are defined as follows:

Notation Title Frequency S

Shift At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D

Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W

Weekly At least once per 7 days BW Biweekly At least once per 14 days M

Monthly At least once per 31 days Q

Quarterly At least once per 92 days SA Semiannual At least once per 184 days A

Annually At least once per 366 days R

Refueling At least once per 18 months P

Start up Prior to Reactor Start up, if not completed in the previous week.

Exception to these intervals are stated in the individual Specifications.

3.0.3 The provisions of Specifications 3.0.1 and 3.0.2 are applicable to all codes and standards referenced within the Technical Specifications. The requirements of the Technical Specifications shall have precedence over the requirements of the codes and standards referenced within the Technical Specifications.

3.0.4 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specifications 3.0.1 and 3.0.2, shall constitute noncompliance with the OPERABILITY requirements for the corresponding Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION.. q.i."m..t. may' be delay'ed for up to21 hours to parmit the complotion Of +ho

-r'ilnewe h

allo

-Ible owtage timm limitc ftoATO ourmnt r ecti 1hue Surveillance Requirements do not have to be performed on inoperable equipment.

3.0.5 If it is discovered that a Surveillance was not performed within its specified surveillance interval, then compliance with the requirement to declare the OPERABILITY requirements for the Limiting Condition for Operation 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 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 <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 OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered.

3-0a Amendment No. 42,2-42.,157

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS BASIS Specifications 3.0.1 through 3.0.54 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c)(3):

"Surveillance requirements are requirements relating to test, calibration, 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 condition of operation will be met."

Specification 3.0.1 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 surveillance that are not performed during refueling outages. The limitation of Specification 3.0.1 is based on engineering judgement 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.

The provisions of Specification 3.0.2 define the surveillance intervals for use in the Technical Specifications. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications. A few surveillance requirements have uncommon intervals. In such a case the surveillance interval shall be performed as defined by the individual specifications.

Specification 3.0.3 extends the testing interval required by codes and standards referenced by the Technical Specifications. This clarification is provided to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities. Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the codes and standards referenced therein. The requirements of regulations take precedence over the TS. Therefore test intervals governed by regulation cannot be extended by the TS. An example of this exception is the Containment Leakage Rate Testing Program.

Specification 3.0.4 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, as defined by the provisions of Specifications 3.0.1 and 3.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for the corresponding Limiting Condition for Operation. Under the provisions Amendment No. 1.22,4 29,45185 3-Ob

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS BASIS (continued) 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 even though the Surveillance Requirements are met. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION 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 3.0.4.

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 of 3.0.1, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action. Further, the failure to perform a surveillance within the provisions of Specification of 3.0.1 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant's Technical Specifications.

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wo d be rrguire*d.th. t..

+re com~pletion of 2as ~u~illance.R The basde for this 2llowance8 WG'clidez considsratiop for plan co.ditio.,

adae..at planning, availability,' of porsonn.l. the time raq.ired to prform. th.

,,r\\,oillap-c-, ard the cft,'

£-*n;f;c-nc-of the dol-; in completing

'thR r41r;,,;W

~rvilanc.

f a£~~eilaceis not complotod within the 214 hou r allowances, the timo s.

.. -a 2r v

v.

Imite of the ACTIOIN reFqaiarements. are appli-able 2lt this t

h Whoa tim.he a,,rllan-per~fomed wihnthe 24 hour-AlloAnceR-0 2Rd-the Su~ilneRaqwiraemots rar not met, the tima ';mots of the ACTION 46ureet are alpplica2blea~t the time tha2tth Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements must be met to demonstrate that inoperable equipment has been restored to operable status.

Amendment No. 122 3-0c

Specification 3.0.5 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 3.0.1, 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 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 surveillance interval 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, Specification 3.0.5 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 3.0.5 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by ACTIONS.

Failure to comply with specified surveillance intervals for Surveillance Requirements is expected to be an infrequent occurrence. Use of the delay period established by Specification 3.0.5 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 surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

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

used to determine the safest course of action. All missed Surveillances will be placed in the corrective action program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the allowable outage time limits of the ACTIONS for the applicable Limiting Condition for Operation 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 allowable outage time limits of the ACTIONS for the applicable Limiting Condition for Operation begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the allowable outage time limits-of the ACTIONS, restores compliance with Specification 3.0.4.

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.19 Containment Leakage Rate Testing Program (Continued)

The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.1% of containment air weight per day.

Leakage Rate acceptance criteria are:

a.

Containment leakage rate acceptance criterion is _< 1.0 La. During unit startup following testing in accordance with this program, the leakage rate acceptance criteria are _< 0.60 La Maximum Pathway Leakage Rate (MXPLR) for Type B and C tests and < 0.75 La for Type A tests.

b.

Personnel Air Lock testing acceptance criteria are:

(1)

Overall Personnel Air Lock leakage is < 0.1 Lawhen tested at > Pa.

(2)

For each PAL door, seal leakage rate is < 0.01 La when pressurized to

__ 5.0 psig.

c.

Containment Purge Valve (PCV-742A/B/ClD) testing acceptance criterion is:

For each Containment Purge Valve, leakage rate is < 18.000 SCCM when tested at _>

Pa.

d.

If at any time when containment integrity is required and the total Type B and C measured leakage rate exceeds 0.60 La Minimum Pathway Leakage Rate (MNLPR), repairs shall be initiated immediately. If repairs and retesting fail to demonstrate conformance to this acceptance criteria within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then containment shall be declared inoperable.

The provisions of Specification 3.0.1 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Specifications 3.0.4 and 3.0.5 are applicable to the Containment Leakage Rate Testing Program.

5.20 Technical Specifications (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.

Amendment No. 445, 202 5-17

b.

Licensees may make changes to 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 USAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the USAR.

d.

Proposed changes that meet the criteria of 5.20.b above shall be reviewed and approved by the NRC prior to implementation. 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).

LIC-02-0066 Page 1 ATTACHMENT 3 Clean-Typed Technical Specification Pages

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.0.1 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.

3.0.2 The surveillance intervals are defined as follows:

Notation Title Frequency S

Shift At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D

Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W

Weekly At least once per 7 days BW Biweekly At least once per 14 days M

Monthly At least once per 31 days Q

Quarterly At least once per 92 days SA Semiannual At least once per 184 days A

Annually At least once per 366 days R

Refueling At least once per 18 months P

Start up Prior to Reactor Start up, if not completed in the previous week.

Exception to these intervals are stated in the individual Specifications.

3.0.3 The provisions of Specifications 3.0.1 and 3.0.2 are applicable to all codes and standards referenced within the Technical Specifications. The requirements of the Technical Specifications shall have precedence over the requirements of the codes and standards referenced within the Technical Specifications.

3.0.4 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specifications 3.0.1 and 3.0.2, shall constitute noncompliance with the OPERABILITY requirements for the corresponding Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. Surveillance Requirements do not have to be performed on inoperable equipment.

3.0.5 If it is discovered that a Surveillance was not performed within its specified surveillance interval, then compliance with the requirement to declare the OPERABILITY requirements for the Limiting Condition for Operation 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 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 <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 OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered.

Amendment No. 12 2,1 2 0,

5 7 3-0a

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.0.5 (continued)

When the Surveillance is performed within the delay period and the Surveillance is not met, the OPERABILITY requirements for the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(S) must be entered.

BASIS Specifications 3.0.1 through 3.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c)(3):

"Surveillance requirements are requirements relating to test, calibration, 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 condition of operation will be met."

Specification 3.0.1 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 surveillance that are not performed during refueling outages. The limitation of Specification 3.0.1 is based on engineering judgement 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.

The provisions of Specification 3.0.2 define the surveillance intervals for use in the Technical Specifications. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications. A few surveillance requirements have uncommon intervals. In such a case the surveillance interval shall be performed as defined by the individual specifications.

Specification 3.0.3 extends the testing interval required by codes and standards referenced by the Technical Specifications. This clarification is provided to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities. Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the codes and standards referenced therein. The requirements of regulations take precedence over Amendment No. 122,129,152,185 3-0b

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS BASIS (continued) the TS. Therefore test intervals governed by regulation cannot be extended by the TS.

An example of this exception is the Containment Leakage Rate Testing Program.

Specification 3.0.4 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, as defined by the provisions of Specifications 3.0.1 and 3.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for the corresponding Limiting Condition for Operation. Under 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 even though the Surveillance Requirements are met. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION 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 3.0.4. 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 of 3.0.1, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action. Further, the failure to perform a surveillance within the provisions of Specification of 3.0.1 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant's Technical Specifications.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements must be met to demonstrate that inoperable equipment has been restored to operable status.

Specification 3.0.5 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 3.0.1, 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 ACTIONS or other remedial measures that might preclude completion of the Surveillance.

3-0c Amendment No.-1 TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS BASIS (continued)

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 surveillance interval 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, Specification 3.0.5 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 3.0.5 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by ACTIONS.

Failure to comply with specified surveillance intervals for Surveillance Requirements is expected to be an infrequent occurrence. Use of the delay period established by Specification 3.0.5 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 surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

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

Amendment No.

3-0d

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS BASIS (continued)

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 allowable outage time limits of the ACTIONS for the applicable Limiting Condition for Operation 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 allowable outage time limits of the ACTIONS for the applicable Limiting Condition for Operation begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the allowable outage time limits-of the ACTIONS, restores compliance with Specification 3.0.4.

Amendment No.

3-0e

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.19 Containment Leakage Rate Testing Program (Continued)

The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.1% of containment air weight per day.

Leakage Rate acceptance criteria are:

d.

Containment leakage rate acceptance criterion is _ 1.0 La. During unit startup following testing in accordance with this program, the leakage rate acceptance criteria are _ 0.60 La Maximum Pathway Leakage Rate (MXPLR) for Type B and C tests and _< 0.75 La for Type A tests.

e.

Personnel Air Lock testing acceptance criteria are:

(3)

Overall Personnel Air Lock leakage is _ 0.1 Lawhen tested at >_ Pa.

(4)

For each PAL door, seal leakage rate is _ 0.01 La when pressurized to

_> 5.0 psig.

f.

Containment Purge Valve (PCV-742A/B/C/D) testing acceptance criterion is:

For each Containment Purge Valve, leakage rate is < 18.000 SCCM when tested at Ž_ Pa.

d.

If at any time when containment integrity is required and the total Type B and C measured leakage rate exceeds 0.60 La Minimum Pathway Leakage Rate (MNLPR), repairs shall be initiated immediately. If repairs and retesting fail to demonstrate conformance to this acceptance criteria within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, then containment shall be declared inoperable.

The provisions of Specification 3.0.1 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of Specifications 3.0.4 and 3.0.5 are applicable to the Containment Leakage Rate Testing Program.

5.20 Technical Specifications (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.

Amendment No. ",

n 2 0 2 5-17

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.20 Technical Specifications (TS) Bases Control Program (continued)

b.

Licensees may make changes to 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 USAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the USAR.

d.

Proposed changes that meet the criteria of 5.20.b above shall be reviewed and approved by the NRC prior to implementation. 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).

Amendment No.

5-18