ML022910304
| ML022910304 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/15/2002 |
| From: | Richard Ennis NRC/NRR/DLPM/LPD1 |
| To: | |
| References | |
| TAC MB5676 | |
| Download: ML022910304 (4) | |
Text
APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued)
- 1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
- 2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
- 3.
At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This specification is not applicable in MODES 5 or 6.
3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.
This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.
Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25%
of the surveillance time interval.
4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <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 Limiting Condition for Operation must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition of Operation must immediately be declared not met, and the applicable Condition(s) must be entered.
4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.
This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.
MILLSTONE - UNIT 2 3/4 0-2 Amendment No.
M, 7J, 07J, 797, 0830 7, 271
BASES (Con't)
Specification 4.0.1 through 4.0.5 establish the general requirements applic able to Surveillance Requirements.
These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, IOCFR50.36(c) (3):
"Surveillance requirements are requirements relating to test, cali bration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."
Specification 4.0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirements.
The purpose of this specification is to ensure that surveillances are performed to verify the OPERABILITY of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable.
Failure to meet a Surveillance within the specified surveillance interval, in accordance with Specification 4.0.2, constitutes a failure to meet a Limiting Condition for Operation.
Systems and components are assumed to be OPERABLE when the associated Surveillance.Requirements have been met.
Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when either:
- a.
The systems or components are known to be inoperable, although still meeting the Surveillance Requirements or
- b.
The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.
Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE or other specified conditions for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.
The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given Surveillance Requirement.
In this case, the unplanned event may be credited as fulfilling the performance of the Surveillance Requirement.
This allowance includes those Surveillance Requirements whose performance is normally precluded in a given MODE or other specified condition.
Surveillance Requirements, including Surveillances invoked by ACTION requirements, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.
Surveillances have to be met and performed in accordance with Specification 4.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.
This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2.
Post maintenance testing may not be MILLSTONE - UNIT 2 B 3/4 0-5a Amendment No. 77, 271 0831
BASES (Con't) possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established.
In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.
This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
Some examples of this process are:
- a.
Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressure > 800 psi.
- However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE.
This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
- b.
High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure.
Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE.
This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
Specification 4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended.
It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g.,
transient conditions or other ongoing surveillance or maintenance activities.
It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval.
It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.
The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.
This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified surveillance interval.
A delay period of up to 24 hours2.777778e-4 days <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 4.0.2, and not at the time that the specified surveillance interval was not met.
This delay period provides adequate time to complete Surveillances that have been missed.
This delay period permits the completion of a Surveillance before complying with Action requirements or other remedial measures that might preclude completion of the Surveillance.
Amendment No.
77, 271 MILLSTONE - UNIT 2 0831 B 3/40O-5b
BASES (Con't)
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable 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 I after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.)
is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance.
However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
Specification 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Action requirements.
Failure to comply with specified surveillance intervals for the Surveillance Requirements is expected to be an infrequent occurrence.
Use of the delay period established by Specification 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 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 licensee's Corrective Action Program.
If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the entry into the ACTION requirements for the applicable Limiting Condition for Operation begins immediately upon expiration of the delay period.
If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and entry into the ACTION requirements for the applicable Limiting Condition for Operation begins immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the applicable ACTIONS, restores compliance with Specification 4.0.1.
MILLSTONE -
UNIT 2 0831 BASES (ton t)
Amendment No. 271 B 3/4 0-6