Text

1 & 2 Issuance of Amendment TS Pages on Missed Surveillances Using Consolidated Line Item Improvement Process
	ML031070078
Person / Time
Site:	Salem
Issue date:	04/16/2003
From:	Robert Fretz; NRC/NRR/DLPM/LPD1
To:	;
References
	TAC MB5825, TAC MB5826
	Download: ML031070078 (15)
	v • d • e

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RESPONSIBILITY..

........ 6-1 6.2 ORGANIZATION Onsite and Offsite Organizations.....

........ 6-1 Facility Staff...................... 6-2 Shift Technical Advisor

....... 6-7 6.3 FACILITY STAFF QUALIFICATIONS

.............. 6-7 6.4 TRAINING....

....... 6-7 6.5 REVIEW AND AUDIT (THIS SECTION DELETED).....

..... 6-8 6.6 REPORTABLE EVENT ACTION............

..... 6-16 6.7 SAFETY LIMIT VIOLATION

... 6-16 6.8 PROCEDURES AND PROGRAMS...........

...... 6-17 6.9 REPORTING REQUIREMENTS 6.9.1 ROUTINE REPORTS

... 6-20 6.9.2 SPECIAL REPORTS

.. 6-24 6.10 RECORD RETENTION

. 6-25 6.11 RADIATION PROTECTION PROGRAM

. 6-26 6.12 HIGH RADIATION AREA..................

. 6-27 6.13 PROCESS CONTROL PROGRAM (PCP).

.......... 6-28 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

......... 6-29 6.15 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS..

.......... 6-29 6.16 ENVIRONMENTAL QUALIFICATION.

........... 6-30 6.17 TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM.

... 6-30 I

SALEM -

UNIT 1 XVIII Amendment No. 256

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the 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 frequency 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 surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

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 Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

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

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met and the applicable Actions 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.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a.

Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

b.

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

SALEM - UNIT 1 3/4 0-2a Amendment No.256

ADMINISTRATIVE CONTROLS C.

A detailed description of the equipment, components and processes involved and the interfaces with other plant systems;

d. An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto;

e. An evaluation of the change, which shows the expected maximum exposures to individual in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto;

f. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made;

g. An estimate of the exposure to plant operating personnel as a result of the change; and

h.

Documentation of the fact that the change was reviewed and found acceptable by the (SORC).

2.

Shall become effective upon review and acceptance by the SORC.

6.16 ENVIRONMENTAL QUALIFICATION 6.16.1 All safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of:

Division of Operating Reactors "Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (DOR Guidelines); or, NUREG-0588 Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," December 1979.

Copies of these documents are attached to Order for Modification of License No. DPR-70 dated October 24, 1980.

6.16.2 Complete and auditable records shall be available and maintained at a central location which describe the environmental qualification method used for all safety related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0588.

Such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified.

6.17 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.

SALEM - UNIT 1 6-30 Amendment No. 256

ADMINISTRATIVE CONTROLS

c.

Proposed changes to the Bases that require either condition of Specification 6.17.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.

M-UNIT 1 6-31 Amendment No. 256 SALE

APPLICABILITY BASES Specifications 4.0.1 through 4.0.5 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 conditions of operation will be met.

Specification 4.0.1 establishes the requirement that Surveillance Requirements must be met during the OPERATIONAL MODES or other specified conditions in the Applicability for which the requirements of the Limiting Conditions for Operation apply, unless otherwise specified in an individual Surveillance Requirement.

This specification is to ensure that surveillances are performed to verify the OPERABILITY of systems and components and that variables are within specified limits.

Failure to meet a Surveillance within the specified Frequency, in accordance with Specification 4.0.2, constitutes a failure to meet an LCO.

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.

Surveillances do not have to be performed when the facility is in an OPERATIONAL MODE or other specified 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.

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

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

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2. Post maintenance testing may not be possible in the current OPERATIONAL 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 SALEM - UNIT 1 B 3/4 0-5 Amendment No. 256

APPLICABILITY BASES the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to an OPERATIONAL 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 pressures > 680 psig. 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 (HPI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

Specification 4.0.2 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 frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified 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 3.0.2, 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.

SALEM - UNIT 1 B 3/4 0-6 Amendment No. 256

APPLICABILITY BASES 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 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 4.0.3 allows for 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 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 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.

SALEM - UNIT I B 3/4 0-7 Amendment No. 256

APPLICABILITY BASES Specification 4.0.4 establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement.

The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility.

This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this could delay placing the facility in a lower MODE of operation.

Specification 4.0.5 establishes the requirement that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a.

These requirements apply except when relief has been provided in writing by the Commission.

This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and 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 ASME Boiler and Pressure Vessel Code and applicable Addenda.

The requirements of Specification 4.0.4 to perform surveillance activities before entry into an OPERATIONAL MODE or other specified condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps and valves to be tested up to one week after return to normal operation.

The Technical Specification definition of OPERABLE does not allow a grace period before a component, that is not capable of performing its specified function, is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before being declared inoperable.

SALEM -

UNIT 1 B 3/4 0-8 Amendment No. 256

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RESPONSIBILITY.....................

6-1 6.2 ORGANIZATION Onsite and Offsite Organizations.........

Facility Staff...........................

Shift Technical Advisor..................

6-1 6-1 6-7 6.3 FACILITY STAFF QUALIFICATIONS...........

................... 6-7 6.4 TRAINING..........

............................. 6-7 6.5 REVIEW AND AUDIT (THIS SECTION DELETED)...

6.6 REPORTABLE EVENT ACTION...................

6.7 SAFETY LIMIT VIOLATION 6.8 PROCEDURES AND PROGRAMS...................

6.9 REPORTING REQUIREMENTS 6.9.1 ROUTINE REPORTS 6.9.2 SPECIAL REPORTS 6.10 RECORD RETENTION..........................

6.11 RADIATION PROTECTION PROGRAM 6.12 HIGH RADIATION AREA.......................

6.13 PROCESS CONTROL PROGRAM (PCP).............

..................6-8

..................6-16

..................6-17

..................6-20

................. 6-24

................. 6-25

................. 6-26

................. 6-27

................. 6-28 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6.15 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS 6.16 TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM 6-29 6-29 6-30 I

SALEM - UNIT 2 XVIII Amendment No.237