ML022190311

PSEG Nuclear, Llc., Application for Amendment to License NPF-57. Amendment Would Modify TS Requirements for Missed Surveillance Tests in TS 4.0.3 Using Consolidated Line Item Improvement Process for Hope Creek

ML022190311
Person / Time
Site:	Hope Creek
Issue date:	07/25/2002
From:	Garchow D Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H02-03, LR-NO2-0037
Download: ML022190311 (16)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 SPSEG UUL~2OIP A~ur'learILLC LR-N02-0037 LCR H02-03 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REGARDING MISSED SURVEILLANCE REQUIREMENTS (T.S. 4.0.3) AND ADOPTION OF TS BASES CONTROL PROGRAM (T.S. 6.5) USING CLIIP HOPE CREEK GENERATING STATION DOCKET NO. 50-354 FACILITY OPERATING LICENSE NO. NPF-57 Gentlemen:

In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) and supporting Bases for the Hope Creek Generating Station. The proposed amendment would modify TS requirements for missed surveillance tests in TS 4.0.3 using the Consolidated Line Item Improvement Process (CLIIP), described in NRC approved industry Technical Specification Task Force (TSTF) change TSTF-358, Revision 6. In conjunction with this change, the submittal incorporates a TS Bases Control Program in TS Section 6.0 consistent with the program described in the Standard Technical Specifications for General Electric BWR/4 Plants (STS), NUREG-1433, Rev. 2, 4/30/01. provides a description of the proposed change, the requested confirmation of applicability and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. summarizes the regulatory commitments made in this submittal and Attachment 4 provides the existing TS Bases pages marked up to show the proposed changes. Pursuant to the STS requirements for TS Bases control, as incorporated into this Amendment request, the revised Bases are being submitted for NRC review and approval.

95-2168 REV. 7/99

Document Control Desk JUL 2 5 2002 LR-N02-0037 The Station Operations Review Committee (SORC) and the Nuclear Review Board (NRB) have reviewed the proposed amendment. Pursuant to the requirements of 10 CFR 50.91 (b)(1), a copy of this request for amendment has been sent to the State of New Jersey.

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

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

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

Sincerely, David F. G~ar how?

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

Document Control Desk UUL 2 5 2002 LR-N02-0037 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. George Wunder, Project Manager - Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08B2 Washington, DC 20555-0001 USNRC Resident Inspector Office (X24)

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

ATTACHMENT 1 LCR H02-03 LR-N02-0037 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM DESCRIPTION AND ASSESSMENT

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

In conjunction with this change, the submittal incorporates a TS Bases Control Program into Section 6.0, consistent with the program described in the Standard Technical Specifications for General Electric BWR/4 Plants (STS), NUREG-1433, Revision 2, 4/30/01.

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

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

ATTACHMENT 1 LCR H02-03 LR-N02-0037 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM supporting Bases in their entirety. There are no substantive differences between the existing SR 4.0.3 and the corresponding STS requirements, only wording.

Therefore, the evaluation and justification presented in TSTF-358 remain fully applicable.

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

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

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

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

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

ATTACHMENT 1 LCR H02-03 LR-N02-0037 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 CHANGE TO TECHNICAL SPECIFICATIONS MISSED SURVEILLANCE AND TS BASES CONTROL PROGRAM Regulatory Guide 1.182, Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants. The Bases further state that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that a missed surveillance for an important component should be analyzed quantitatively. The results of the risk evaluation should determine the appropriate course of action.

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

4. ENVIRONMENTAL EVALUATION PSEG has reviewed the environmental evaluation included in the model safety evaluation from 66FR32400 dated June 14, 2001 and has concluded that the staff's findings presented in the evaluation are applicable to Hope Creek. The evaluation is hereby incorporated by reference into this application.

5. REFERENCES

1. Industry/Technical Specification Task Force Standard Technical Specification Change Traveler, TSTF-358, Rev. 6; Missed Surveillance Requirements.

2. Federal Register 66FR32400, Notice of Opportunity to Comment on Model Safety Evaluation on TS Improvement to Modify Requirements Regarding Missed Surveillances Using CLIIP, dated June 14, 2001.

3. Federal Register 66FR49714, Notice of Availability of Model Application Concerning TS Improvement to Modify Requirements RegardingMissed Surveillances Using CLIIP, dated September 28, 2001.

4. Letter W. D. Beckner (NRC) to A. R. Pietrangelo (NEI) approving TSTF-358, Rev. 6, dated October 3, 2001,

5. NUREG-1433, Rev. 2, Standard Technical Specifications for GeneralElectric BWRI4 Plants

ATTACHMENT 2 LCR H02-03 LR-N02-0037 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Hope Creek, Facility Operating License NPF-57, are affected by this change request:

Technical Specification Paqe 4.0.3 3/4 0-2 6.15 6-25, 6-26 Bases 4.0.3 B 3/4 0-4, B 3/4 0-5

ATTACHMENT 2 LCR H02-03 LR-N02-0037 HOPE CREEK MARKED-UP TECHNICAL SPECIFICATION PAGES Insert A (Completely replaces existing 4.0.3)

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

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met and the applicable Actions must be entered.

When a Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met and the applicable Actions must be entered.

SURVEILLANCUA REUREE 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS 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 its specified surveillance interval with a maximum-allowable extension not to exceed ACTION rqie myb eae o pt 4hus pri h completina- urelacwhntellw le eteliisoth o be performeda on inoperable t.

4.0.4 Entry into an OPERtATIONAL CONI*DTION or other specified applicable condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comerply with ACTiON requirements.

4m.0.5 Surveillance Requirements for inserice inspection and testing of ASMEd Code Class 1, 2, & 3 compnensc shall be applicable as fellows:

a. Inservice inspection of ASt.3 Code Class 1, 2, and 3 components and inservice testing of AS2I Code Class 1, 2, and 3 pumps and valves aedll be performed in accordance with Section X. of the AS4bin Boiler and Pressure Vessel Code and applicable Addenda as required by 10 unl s0 Sections 0.SSa(f) R and 0.e a(g), excepted where specific written relief has been granted by the Commission pursuant to 10 CI 50. Section S0.S~a(f) (6) (i) or Section 5O.S5a(g) (6) (i).

b. Surveillance intervals specified in Section XI of the Coiler and cpe Vessel Code and aplicable Addenda for the tssre inservice inspection and testing activities required by the ASH!

Boiler and HOPE CREEK 3/4 0-2 Amendment No. 1 01

ATTACHMENT 2 LCR H02-03 LR-N02-0037 Insert B (New TS 6.15) 6.15 TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. PSEG may make changes to the Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the License, or

2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. Proposed changes to the Bases that require either condition of Specification 6.15.b above shall be reviewed and approved by the NRC prior to implementation.

d. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

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

ADMINISTRATIVE CONTROLS 6.13 PROCESS CONTROL PROGRAM (PCP) 2fan-es to the PC?:

a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.3.n. This daocwsmentation shall contain:

I11) Sufficient information to support the change together wi:n the appropriate analyses or evaluations justifying !:,e changes(s) and (2) A determination that the cnange will maintain the overal conformance of the solidified waste product to eKisting requirements of Federal, State, or other applicable regulations.

b. Shall become effective after review and acceptance by the SORC and the approval of the Plant General Manager.

6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

.- anges to the ODCM:

a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.3.n. This documentation shall contain:

1) Sufficient information to support the change together wi:-. t:-e appropriate analyses or evaluations justifying the changes(s:

and

2) A determination that the change will maintain the level :f radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Par: 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b. Shall become effective after review and acceptance by the SORC and the approval of the Plant General Manager.

Z. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent wi..

the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each znange shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month/year) the change was i.mplemented.

"a - .5.4 6-25 Amendment No. 121

ATTACHMENT 3 LCR H02-03 LR-N02-0037 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by PSEG in this document. Any other statements in this submittal are provided for information only purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Carl Berger at (856) 339-1432.

Regulatory Commitment Due DatelEvent PSEG will establish the Technical Specification Bases for Concurrent with SR 4.0.3 as adopted with this license amendment request. implementation of the amendment PSEG will establish a Technical Specification Bases control Concurrent with program consistent with this submittal. implementation of Ithe amendment

ATTACHMENT 4 LCR H02-03 LR-N02-0037 PROPOSED CHANGES TO TS BASES PAGES Insert C (Replacesexisting Bases for TS 4.0.3)

Surveillance 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable, or an affected variable outside the specified limits, when a Surveillance has not been completed within the specified frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with TS 4.0.2, and not at the time that the specified frequency was not met.

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

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering Mode 1 after each fuel loading, or in accordance with 10CFR50 Appendix J, as modified by approved exemptions, etc.) is discovered not to have been performed when specified, SR 4.0.3 allows the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity. SR 4.0.3 also provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified frequencies for Surveillances is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit

ATTACHMENT 4 LCR H02-03 LR-N02-0037 conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable, or the variable is considered outside the specified limits, and the Completion Times of the Required Actions for the applicable LCO begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits, and the Completions Times of the Required Actions for the applicable LCO begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the Actions, restores compliance with SR 4.0.1.

3/4.0 APPLICABILITY BASES (Con't)

Specifications 4.0.1 through 4.0.5 establish the general requirements appli cable 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 conditions of operation will be met."

Spe ification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL CONDITIONS or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. 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 an OPERATIONAL CONDITION or other specified condition for which the individual Limiting Conditions for Operation are applicable. Surveillance Requirements do not have to be performed when the facilitj is in an OPERATIONAL CONDITION 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 establishes the limit for which the specified time interval for Surveillance Requirements my 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 surveillan4.* being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the I reliability ensured through surveillance activities is not significantly degraded beyond that obtain om haa 111 S ecification 4.0.3 establishes the failure to perform a,SReequi r w sseif 1M- - as a ,edtime t r. Htar, nh inaythe provisions of Spectftcati'on-4.0.2, condition n Ifa Iure to lost

• OPERABILITY reqluient ssting Condtiton for t o.~r the Sprovi sionsefti cfctossesadcmoeasb SAmendment No. 37 APR 3 WO9 I

3/4.0 APPLICABILITY BASES (Con't) be construed as I ying that syst or components are RABLE when they are found or known to

• inoperable a hough still meeti Surveillance Mequireý mints. This sp ification also larities that the ION requi rements are applicable vh Surveilla~nce quirements have no eon completed withi the allowed surv l~ance interv and that the ti imits of the ACTION Uir*

Monts appi from the poin n time it is ids fled that a surveil rce has noat

b*een eXCeeds nd and nota the time that th allowed survalllanc riterval was pe:rt.completion the Suriieillan Requirement within allowable

Outca~g tine limits o the ACTION requ' ements rustores c ance with the requ ements osfiS: cif ication 4.0.3 However, this does at negate the fact th the failure o have pertorme the surveillance wi in the allowed surveil I a inteoval definted by the ovislons of Specif atlon 4.0.2, was a v Ia aon of the 0 RABILITY requl nts of a Limiti Condition for Opera on th is subject enforcement Ion. Further. th allure to perform urvail lance wt nithe provisi of Specification .0.2 is a violatla f a Techni-j Cal Soe ticatlon reQu sment and is,the one, a reportable ent under the requir ents of 10 CF 50.73(a)(2)(i)(B eCause it is a Co tion prohibited by th plant's Tic ical Specificatlo If he allowab outage time 113 s of the ACTION r irements are less t 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or shutdown is requ d to comply wit TION reqirements, .g..

Speclficat, n 3.0.3., a 24- r allowance is p ided to permi t a y in Implemon ng the ACTION r irteents. This vides an adequate me limit to com~plIe Surveillance R irements that h not been pertormus . The purpose ot t *sallowance is permit the cam ion of a surveill a before a sh don would be r uired to comply th ACTION requl ts or before other dial measures uld be require hat may preclude completion of a surveillance. - basis for thi allowance Includes *nsideratlon for plan conditions, a quate pl~anning availability of per nnel, the time required perform the urveillance, a the safety signif ance of the delay in Comletin required sve the completi ilance. This p vision also provides a immit f the of Surveillance ft irements that become Icaoi as aýnsequance of ITION changes I ad by ACTION requl s and to c ting Sw'voil nce Requirements tt are applicable when exception 0 the requi rement of Specification 4 .4 isallowed. It a s allilance isnot completed wit n the 24-hour all nce, the tine limits a h ACTION requirement are applicable at at time. When a surv lance is pert.

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