ML022140112
| ML022140112 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/30/2002 |
| From: | NRC/NRR/DLPM |
| To: | |
| References | |
| TAC MB4874, TAC MB4875 | |
| Download: ML022140112 (5) | |
Text
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per..
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and-the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued) 3.0-4 Amendment Nos. 205/186 McGuire Units 1 and 2
SR Applicability B 3.0 BASES SR 3.0.2 (continued)
"once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One is that reason for not allowing the 25% extension to this Completion Time such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or the action accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified, SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified is Frequency, whichever is greater, applies from the point in time that it discovered that the Surveillance has not been performed in accordance not with SR 3.0.2, and not at the time that the specified Frequency was met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the result of required Surveillance, and the recognition that the most probable any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a Frequency based not on time intervals, b-ut upon specified unit conditions, operating situations, or requirements of in regulations (e.g., prior to entering MODE 1 after each fuel loading, or accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified time Frequency to perform the Surveillance. However, since there is not a be performed at the first interval specified, the missed Surveillance should reasonable opportunity.
B 3.0-11 Revision No. 29 McGuire Units 1 and 2
SR Applicability B 3.0 BASES SR 3.0.3 (continued)
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.'
This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.
If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.
McGuire Units 1 and 2 B 3.0-12 RZevision No. 29
SR Applicability B 3.0 BASES SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.
This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability of for which these systems and components ensure safe operation the unit.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring an systems or component to OPERABLE status before entering associated MODE or other specified condition in the Applicability.
not However, in certain circumstances, failing to meet an SR will result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed.
Therefore, failing to perform the Surveillance(s) within the to specified Frequency does not result in an SR 3.0.4 restriction changing MODES or other specified conditions of the Applicability.
However, since the LCO is not met in this instance, LCO 3.0.4 will or govern any restrictions that may (or may not) apply to MODE other specified condition changes.
The provisions of SR 3.0.4 shall not prevent changes in MODES required or other specified conditions in the Applicability that are to comply with ACTIONS.
The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicabilitof of a the associated LCO prior to the performance or completion Surveillance. A Surveillance that could not be performed until after entering the LCO Applicability, would have its Frequency specified such that it is not "due" until the specific conditions in needed are met. Alternately, the Surveillance may be stated until a the form of a Note as not required (to be met or performed)
SR 3.0.4 (continued)
B 3.0-13 Revision No. 29 McGuire Units 1 and 2 i ý,
SR Applicability B 3.0 BASES particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.
to SR 3.0.5 SR 3.0.5 delineates the applicability of the surveillance activities Unit 1 and Unit 2 operations.
B 3.0-14 FRevi si on No. 29 McGuire Units 1 and 2