NRC Generic Letter 1987-09
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C.20555 June 4, 1987 TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTS
Gentlemen:
SUBJECT: SECTIONS 3.0 AND 4.0 OF THE STANDARD TECHNICAL SPECIFICATIONS (STS)
ON THE APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION AND
SURVEILLANCE REQUIREMENTS (Generic Letter 87-09)
As a part of recent initiatives to improve Technical Specifications (TS), the NRC, in cooperation with the Atomic Industrial Forum (AIF), has developed a program for TS improvements. One of the elements of this program is the implementation of short-term improvements to resolve immediate concerns that have been identified in investigations of TS problems by both NRC and AIF.'
The guidance provided in this generic letter addresses three specific problems that have been encountered with the general requirements on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the STS.
There are five enclosures to this Generic Letter. Enclosure 1 applies to both PWR and BWR STS and provides a complete discussion of the three problems and the staff's position on acceptable modifications of the TS to resolve them. These modifications should result in improved TS for all plants and are consistent with the recommendations of NUREG-1024, Technical Specifications --
Enhancing the Safety Impact' and the Commission Pojicy Statement on Technical Specification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 of the PWR and BWR STS, respectively, which incorporate the modifications being made by this Generic Letter. Enclosures 3 and 5: (a) provide the staff's update of the bases for the PWR and BWR STS, respectively; (b) reflect the modifications of Sections 3.0 and 4.0 of the STS; and (c) include improved bases for the unchanged requirements in these sections.
The staff concludes that these modifications will result in improved TS for all plants. Licensees and applicants are encouraged to propose changes to their TS that are consistent with the guidance provided in the enclosures;
however, these changes are voluntary for all licensees and current OL
applicants.
The staff would like to point out three important points connected with the present TS effort. First, it is aware that the TS can be clarified, simplified, and streamlined both as a whole and with respect to the specifications that are the subject of this Generic Letter. Nonetheless, in keeping with its short-term and purposefully narrow focus, it decided to keep these proposed modifications: (a) focused on the three problems; (b) relatively simple; and (c)consistent with the phrasing of existing TS. Second, after the resolution of these and other identified TS problems, the staff will notify licensees and applicants of its conclusions and resulting proposals for additional short-term TS improvements. Finally, the staff is not proposing to formally amend the STS at this time. Instead the changes will be factored Into the development of the new STS anticipated as a part of the implementation of the Commission's Policy Statement on Technical Specification Improvements.
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2 The following is a summary of the three problems covered by the enclosures.
The first problem involves unnecessary restrictions on mode changes by Specification 3.0.4 and inconsistent application of exceptions to it. The practical solution is to change this specification to define the conditions under which its requirements apply. With respect to unnecessary mode changes, Specification 3.0.4 unduly restricts facility operation when conformance with Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements. The solution also resolves the problem of inconsistent application of exceptions to Specification 3.0.4: (a)which'
delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility; and (b)which delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.
The second problem involves unnecessary shutdowns caused by Specification
4.0.3 when surveillance intervals are inadvertently exceeded. The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO. It is overly conservative to assume that systems or components -re inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for performing a missed surveillance before Shutdown Requirements apply, the TS should include a time limit that allows a delay of required actions to permit the performance of the missed surveillance based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and, of course, the safety significance of the delay in completing the surveillance. The staff has concluded 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 times of the Action Requirements are less than this limit, or when time is needed to obtain a temporary waiver of the Surveillance Requirement.
The third problem involves two possible conflicts between Specifications 4.0.3 and 4.0.4. The first conflict arises because Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. A conflict with this requirement exists when a mode change is required as a consequence of Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. Specification 4.0.4 should not be used to prevent passage through or to operational modes as required to comply with Action Requirements because to do so: (a)would increase the potential for a plant
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3- upset; and (b) would challenge safety systems. Also, certain surveillances should be allowed to be performed during a shutdown to comply with Action Requirements. Along with the modification of Specification 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of Action Requirements, Specification 4.0.4 has been clarified to allow passage through or to operational modes as required to comply with Action Requirements.
A second conflict could arise because, when Surveillance Requirements can only be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed. However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore, to avoid any conflict between Specifications
4.0.3 and 4.0.4, the staff wants to make clear: (a) that it is not the intent of Specification 4.0.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to Specification 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability of Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of allowance of any exception to Specification 4.0.4.
If you have any questions on this matter, please contact your project manager.
Sincerely, Original signea oy Frank J. Xtreglia Frank J. Miraglia, Associate Director for Projects Office of Nuclear Reactor I Regulation Enclosures:
As stated (SECTIONS 3.0 AND 4.0) *See previous concurrence TSB:DOEA:NRR TSB:DOEA:NRR C:TSB:DOEA:NRR D:DOEA:NRR
- TGDunning *DCFischer *EJButcher *CERossi
05/ /87 05/ /87 05/ /87 05/ /87 AD:ADT:NRR
- RWStarostecki F gli a
05/ /87 0 4 /87
Enclosure 1 to Generic Letter 87-09 ALTERNATIVES TO THE STS REQUIREMENTS TO RESOLVE
THREE SPECIFIC PROBLEMS WITH LIMITING CONDITIONS
FOR OPERATION AND SURVEILLANCE REQUIREMENTS
INTRODUCTION
Generic Letter 87-09 discusses three problems regarding the general requirements of Sections 3.0 and 4.0 of the STS on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements. The guidance provided in this enclosure addresses alternatives to the Standard Technical Specifications (STS) to resolve these problems.
Problem #1 -- UNNECESSARY RESTRICTIONS ON MODE CHANGES (Specification 4.0.3)
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BACKGROUND
The definition of an LCO is given in 10 CFR 50.36 as the lowest functional capability or performance level of equipment required for safe operation of the facility. Further, it is stated that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.
Consistent with NRC's regulatory requirements for an LCO, the TS include two basic types of Action Requirements that are applicable when the LCO is not met. The first specifies the remedial actions that permit continued operation of the facility not restricted by the time limits of Action Requirements. In this case, conformance to the Action Requirements 'rovides an acceptable level of safety for continued operation of the facility, and operation may proceed indefinitely as Iong as the remedial Action Requirements are met. The second type of Action Requirement specifies a time limit in which the LCO must be met. This time limit is the time allowed to restore an inoperable system or component to operable status or to restore parameters within specified limits.
If these actions are not completed within the allowable outage time limits, action must be taken to shut down the facility by placing it in a mode or condition of operation in which the LCO does not apply.
Specification 3.0.4 of the STS states that entry into an operational model or other specified condition shall not be made unless the LCO is met without reliance on the provisions of the Action Requirements. Its intent is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits. This precludes a plant startup when actions are being taken to satisfy an LCO, which -- if not completed within the time limits of the Action Requirements -- would result in a plant shutdown to comply with the Action Requirements.
"operational mode" that is used in PWR STS. As used here, operational mode"
means "operational condition" for BWRs.
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Specification 3.0.4 also precludes entering a mode or specified condition if an LCO is not met, even if the Action Requirements would permit continued operation of the facility for an unlimited period of time. Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply. However, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well documented. For example, approximately two-thirds of the actions which permit continued operation in the Westinghouse STS are exempt from Specification
3.0.4. Although the staff encourages the maintenance of all plant systems and components in an operable condition as a good practice, the TS generally have not precluded entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operation.
o STATEMENT OF THE PROBLEM
Inconsistent application of exceptions to Specification 3.0.4 impacts the operation of the facility in two ways. First, it delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility.
Second, it delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.
In this case, the LCO must be met without reliance on the Action Requirements before returning the facility to that operational mode or other specified condition for which unlimited continued operation was previously permitted in accordance with the Action Requirements.
o STAFF POSITION
Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements. This is consistent with NRC's regulatory requirements for an LCO. The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required. However, nothing in this staff position should be interpreted as endorsing or encouraging a plant startup with inoperable equipment. The staff believes that good practice should dictate that the plant startup should normally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rule.
o CHANGE TO SPECIFICATION 3.0.4 The practical solution to this problem is not the modification of TS to note that Specification 3.0.4 does not apply, but rather a change to Specification
3.0.4 to define the conditions under which its requirements do apply.
Therefore, Specification 3.0.4 will be revised to state:
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Entry into an OPERATIONAL MODE or other specified condition shall not be uade when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time."
° CHANGES TO INDIVIDUAL SPECIFICATIONS EXEMPT FROM SPECIFICATION 3.0.4 As a consequence of the modification described above to Specification 3.0.4, individual specifications with Action Requirements permitting continued operation no longer need to indicate that Specification 3.0.4 does not apply. They should be revised to delete the noted exception to avoid confusion about the applicability of Specification 3.0.4. However, exceptions to Specification
3.0.4 should not be deleted for individual specifications if a mode change would be precluded by Specification 3.0.4 as revised. For example, some specifications would not satisfy the provisions under which mode changes are permitted by the revision to Specification 3.0.4 and, therefore, the exception to Specification
3.0.4 need not be deleted. It is not the staff's intent that the revision of Specification 3.0.4 should result in more restrictive requirements for individual specifications.
Problem #2 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSING
OF SURVEILLANCE INTERVALS (Specification 4.0.3)
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BACKGROUND
Surveillance Requirements are defined in 10 CFR 50.36 as those requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that the facility will be within the safety limits, and that the LCO will be met.
Consistent with the NRC's regulatory framework for Surveillance Requirements, Specification 4.0.3 states that the failure to perform a surveillance within the specified time interval shall constitute a failure to meet the LCO's Operability Requirements. Therefore, if a Surveillance Requirement is not met as a result of the failure to schedule the performance of the surveillance, the LCO would not be met. Consequently, the LCO's Action Requirements must be met as when a surveillance verifies that a system or component is inoperable.
Generally, the Action Requirements include a specified time interval (i.e.,
allowable outage time limit) that permits corrective action to be taken to satisfy the LCO. When such a specified time interval is included in the Action Requirements, the completion of a missed surveillance within this time interval satisfies Specification 4.0.3.
O STATEMENT OF PROBLEM
Some Action Requirements have allowable outage time limits of only one or two hours and do not establish a practical time limit for the completion of a missed Surveillance Requirement. If surveillances cannot be completed within these
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time limits, a plant shutdown would usually be required. Even if the Action Requirements include remedial measures that would permit continued operation, they may be stated In such a way that they could prevent the performance of the required surveillance. A plant shutdown would also be required if the missed surveillance applies to more than the minimum number of systems or components required to be operable for operation under the allowable outage time limits of the Action Requirements. In this case, the individual specification or Specification 3.0.3 would require a shutdown.
If a plant shutdown is required before a missed surveillance is completed, it is likely that it would be conducted when the plant Is being shut down because completion of a missed surveillance would terminate the shutdown requirement.
This is undesirable since it increases the risk to the plant and public safety for two reasons. First, the plant would be in a transient state Involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested. This would occur when the system or component is either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance interval was exceeded. If the surveillance did demonstrate that the system or component was inoperable, it usually would be preferable to restore it to operable status before making a major change in plant operating conditions. Second, a shutdown would increase the pressure on the plant staff to expeditiously complete the required surveillance so that the plant could be returned to power operation. This would further increase the potential for a plant upset when both the shutdown and surveillance activities place a demand on the plant operators.
0 STAFF POSITION
It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The opposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are 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. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the TS should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.
This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance. After reviewing possible limits, the staff has concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.
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Although a missed surveillance would generally be completed in less time than this 24-hour limit allows, special circumstances may require additional time to ensure that the surveillance can be conducted in a safe manner. The time limits of Action Requirements for surveillances should start when it is identified that Surveillance Requirements have not been performed, except when the 24-hour delay is allowed in the implementation of the Action Requirements.
Where the 24-hour time limit is allowed, the time limits of the Action -
Requirements are applicable either at the end of the 24-hour limit if the surveillance has not been completed or at the time the surveillance is performed if the system or component is found to be inoperable.
Several issues need to be clarified regarding the additional 24-hour time limit. First, this limit does not waive compliance with Specification 4.0.3.
Under Specification 4.0.3, the failure to perform a Surveillance Requirement will continue to constitute noncompliance with the Operability Requirements of an LCO and to bring into play the applicable Action Requirements.
Second, Specifications 3.0.2 and 4.0.3 should not be misinterpreted.
Specification 3.0.2 notes that a TS is being complied with when the Action Requirements are met within the specified time intervals. Although Specification 4.0.2 provides an allowance for extending the surveillance interval and allows for the completion of the surveillance within this time interval without violation of this Specification, under Specification 4.0.3 nonperformance of a Surveillance Requirement, within the allowed surveillance interval defined by Specification 4.0.2, constitutes a violation of the Operability Requirements of an LCO, as defined by Specification 4.0.3, and is subject to enforcement action.
To avoid any conflict among or misreading of Specffications 3.0.2, 4.0.3, and
4.0.2, the staff wishes to make clear (1) that Specification 3.0.2 shall not be construed to imply that the completion of a missed surveillance within the allowable outage time limits of the Action Requirements -- whether or not the additional 24-hour time limit is included -- negates the violation of Specification 4.0.3, and (2) that the failure to perform a surveillance within the allowable surveillance interval defined by Specification 4.0.2 constitutes a reportable event under 10 CFR 50.73(a)(2)(1)(B) because it is a condition prohibited by the plant's TS.
Third, even though an additional 24-hour time limit may apply for missed surveillances, another consideration is the possibility that plant conditions may preclude the performance of the specified requirements. The provision of a
24-hour delay in the application of the Action Requirements for the completion of a missed surveillance would provide time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of current plant conditions. If a surveillance can be performed only when the plant is shut down, there are only two options available to licensees when a missed surveillance is discovered during power operation and continued operation is not allowed under the Action Requirements. The first is to shut down the plant and perform the required surveillance. The other option is to seek relief from the Surveillance Requirement. Such relief would result in the processing of a TS amendment. As a matter of existing policy, a temporary waiver of compliance with a TS that would unnecessarily require a shutdown or
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delay startup absence of some relief may be granted by NRC. A temporary waiver of compliance may be granted if the licensee has demonstrated in a written submittal, provided before the TS LCO expired, that the facility can safely continue to operate without compliance with the TS during the time it will take to process the TS amendment request.
° CHANGE TO SPECIFICATION 4.0.3 Specification 4.0.3 will be revised as follows to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO
and to clarify the applicability of the Action Requirements and the time during which the limits apply:
"Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a 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 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 />."
Specification 4.0.3 previously included the statement that exceptions to it are stated in individual specifications. This statement is deleted because Specification 4.0.3 Is always applicable, i.e., the implied exceptions for individual specifications do not exist.
Problem 13 -- CONFLICTS BETWEEN SPECIFICATIONS 4.0.3 AND 4.0.4 RELATED TO MODE CHANGES (Specification 4.0.4)
There are two parts of the general problem of conflicts between Specifications
4.0.3 and 4.0.4 related to mode changes. Each of these parts is discussed separately below.
Part 1 -- SURVEILLANCE REQUIREMENTS THAT BECOME APPLICABLE DUE TO ACTION
REQUIREMENTS
0 STATEMENT OF THE PROBLEM
Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. First, a conflict with this TS exists when a mode change is required as a consequence of shutdown Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. For instance, the plant could previously have been in a mode for which the Surveillance Requirements were not applicable and, therefore, the surveillance may not have been performed within the specified time interval. Consequently, the Action Requirements of the LCO associated with these Surveillance Requirements apply and the unit may have to be placed in a lower mode of operation than that required by the original shutdown Action Requirements, or other remedial actions may have to be
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taken, if the surveillance cannot be completed within the time limits for these actions. This is a second problem that may be encountered.
The first problem arises because conformance with Specification 4.0.4 would require the performance of these surveillances before entering a mode for which they apply. Source and intermediate range nuclear instrumentation and cold overpressure protection systems in PWRs are examples of systems for which Surveillance Requirements may become applicable as a consequence of mode changes to comply with shutdown Action Requirements. The second problem has been mitigated by the change in Specification 4.0.3 to permit a delay of up to
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, thereby placing an appropriate time limit on the completion of Surveillance Requirements that become applicable as a consequence of mode changes to comply with Action Requirements. However, the first problem can be further resolved by a change to Specification 4.0.4.
e C STAFF POSITION
The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with Action Requirements.
It is not the intent of Specification 4.0.4 to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements. Accordingly, Specification, 4.0.4 should be modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements. A similar provision is included in Specification 3.0.4.
0 CHANGE TO SPECIFICATION 4.0.4 The following will clarify Specification 4.0.4 for mode changes as a consequence of Action Requirements:
- This provision shall not prevent passage through or to OPERATIONAL MODES
as required to comply with ACTION Requirements.
Part 2 -- SURVEILLANCE REQUIREMENTS FOR EXCEPTIONS TO SPECIFICATION 4.0.4
0 STATEMENT OF THE PROBLEM
An exception to Specification 4.0.4 is allowed when Surveillance Requirements can be completed only after entry into a mode or specified condition for which they apply. For example, the TS on power distribution limits are generally exempt from Specification 4.0.4. However, upon entry into the mode or specified condition, Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Generally, these Surveillance Requirements apply to redundant systems, and Specification 3.0.3 would apply because they are treated as inoperable under Specification 4.0.3. Therefore, allowance of an exception to Specification 4.0.4 can create a conflict with Specification 4.0.3.
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° STAFF POSITION
It is not the intent of Specification 4.0.3 that the Action Requirements should preclude the performance of surveillances when an exception to Specification
4.0.4 is allowed. However, since Specification 4.0.3 has been changed to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, an appropriate time limit now exists for the completion of those Surveillance Requirements that become applicable when an exception to Specification 4.0.4 is allowed.
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Enclosure 2 to Generic Letter 87-09
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
3/4.0 APPLICABILITY
[NOTE: Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, as shown In the underlined provisions. The other specifications are shown for information only.]
LIMITING CONDITIONS FOR OPERATION
3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.
3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.
3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place it, as applicable, in:
a. 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 />, b. 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 c. 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 />.
Where corrective measures are completed that permit operation under the ACTION
requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.
This specification is not applicable in MODES 5 or 6.
3.0.4 Entry Into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met withT-na specifie time interval. Entry into anOPERATIONAL MODE or secified Condition maX be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage trough or to OPERATIONAL
MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated inthe individual specifications.
APPLICABILITY
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.
4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:
a. A maximum allowable extension not to exceed 25% of the surveillance interval, but b. The combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.
4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILI TY requirements for a 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 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 />. Surveillance Requirements do not have to be performed on inoperjble equipment.
4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with a Limiting Condition of Operation has been performed within the stated surveillance interval or as otherwise specified. This provision shall not pervent 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 PWR STS 3/4.0-2
a- t. vs APPLICABILITY
SURVEILLANCE REQUIREMENTS
Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:
ASME Boiler and Pressure Vessel Required frequencies Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities activities weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days c. The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities.
d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.
e. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements Rf any Technical Specification.
Enclosure 3 to Generic Letter 87-09
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
3/4.0 APPLICABILITY-
LNOTE: This enclosure provides revised Bases for all specifications in Sections 3.0 and 4.0.)
BASES
Specification 3.0.1 through 3.0.4 establish the general requirements applicable to Limiting Conditions for Operation. These requirements are based on the requirements for Limiting Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):
"Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met."
Specification 3.0.1 establishes the Applicability statement within each individual specification as the requirement for when (i.e., in which OPERATIONAL MODES or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility. The ACTION requirements establish those remedial measures that must be taken within specified time limits when the requirements of a Limiting Condition for Operation are not met.
There are two basic types of ACTION requirements. the first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in a MODE or condition in which the specification no longer applies. It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Surveillance Requirement when equipment is removed from service. In this case, the allowable outage time PWR STS B 3/4.0-1 .
- -. .-
3/4.0 APPLICABILITY
BASES (Con't)
limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.
Specification 3.0.2 establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that
(1)implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.
Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.
The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not Wntended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.
If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION
requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.
3/4.0 APPLICABILITY
BASES (Con't)
The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in the COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE of operation. If the plant is in a lower MODE of operation when a shutdown is required, the time limit for reaching the next lower MODE of operation ap- plies. However, if a lower MODE of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other applicable MODE, is not reduced. For example, if HOT STANDBY is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the time allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total time to reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowied.
The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that Is applicable when a Limiting Condition for Operation is not met in a lower MODE of operation.
The shutdown requirements of Specification 3.0.3 dA not apply in MODES 5 and
6, because the ACTION requirements of individual specifications define the remedial measures to be taken.
Specification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for pIeration is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensure that facility operation Is not initiated or that higher MODES of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an accept- able level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.
3/4.0 APPLICABILITY
BASES (Con't)
When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operation.
Specifications 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requ1rements stated in the Code of Federal Regulations,
'Surveillance requirements are requirements relating to test, calibra- tion, 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 performed durtng the OPERATIONAL MODES 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 speci- fication is to ensure that surveillances are performed to verify the opera- tional status of systems and components and that parameters are within speci- fied 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. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MTDE 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 conditions under which the specified time interval for Sur~vellance Requirements may be extended. Item a. 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. Item b. limits the use of the provisions of item a. to ensure that it is not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are 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. These provisions are 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 failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the PWR STS B 3/4.0-4
3/4.0 APPLICABILITY
BASES (Con't)
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 although still meeting the Surveillance Requirements. 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 4.0.3. 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 4.0.2, 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 4.0.2 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.
If 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 /> or a shutdown is required to comply with ACTION requirements, e.g.,
Specification 3.0.3, a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If-a surveillance is not completed within the
24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION
requirements are applicable at the time that the surveillance is terminated.
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 have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.
3/4.0 APPLICABILITY
BASES (Con't)
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 would 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.
i=~
- t *.
Enclosure 4 to Generic Letter 87-09
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
3/4.0 APPLICABILITY
[NOTE: Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, as shown In the underlined provisions. The other specifications are shown for information only.]
LIMITING CONDITIONS FOR OPERATION
3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.
3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.
3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in:
1. At least STARTUP 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 />.
Where corrective measures are completed that permit operation under the ACTION
requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.
This specification is not applicable in OPERATIONAL CONDITION 4 or 5.
3.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION recuires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL CONDITION or other specified condition may be made in accordance with the ACTION requirements when conformance to them permits continued opeaton of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.
Exceptions to these requirements are stated in the individual Specifications.
- si'/~u APPLICABILITY
SURVEILLANCE REQUIREMENTS 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 the specified time interval with: -
a. A maximum allowable extension not to exceed 25% of the surveillance interval, but b. The combined time interval for any 3 consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.
4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a 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 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 />. Surveillance Requirements do not have to be performed on inoperable equipment.
4.0.4 Entry into an OPERATIONAL CONDITION 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 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 BWR STS 3/4.0-2
i .
I
APPLICABILITY
SURVEILLANCE REQUIREMENTS
Pressure Vessel Code and applicable Addenda shall be applicable as follows In these Technical Specifications:
ASME Boiler and Pressure Vessel Required frequencies Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days c. The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities.
d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.
e. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements ;f any Technical Specification.
' I
Enclosure 5 to Generic Letter 87-09
3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS
3/4.0 APPLICABILITY
LNOTE: This enclosure provides revised Bases for all specifications in.
Sections 3.0 and 4.0.)
BASES
Specifications 3.0.1 through 3.0.4 establish the general requirements applicable to Limiting Conditions for Operation. These requirements are based on the requirements for Limiting Conditions for Operation stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):
"Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met."
Specification 3.0.1 establishes the Applicability statement within each individual specification as the requirement for when (i.e., in which OPERATIONAL CONDITIONS or other specified conditions) conformance to the Limiting Conditions for Operation is required for safe operation of the facility. The ACTION requirements establish those remedial measures that must be taken within specified time limits when the requirements of a Limiting Condition for Operation are not met. It is not intended that the shutdown ACTION requirements be used as an operational convpnience which permits (routine) voluntary removal of a system(s) or componentfs) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.
There are two basic types of ACTION requirements. The first specifies the remedial measures that permit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the Limiting Condition for Operation must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these actions are not completed within the allowable outage time limits, a shutdown is required to place the facility in an OPERATIONAL CONDITION or other specified condition in which the specification no longer applies.
The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a Limiting Condition for Operation is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed from service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a Surveillance Requirement when BWR STS B 3/4.0-1
3/4.0 APPLICABILITY
BASES (Con't)
equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered an OPERATIONAL
CONDITION in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not met.
Specification 3.0.2 establishes that noncompliance with a specification exists when the requirements of the Limiting Condition for Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that
(1) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirements.
Specification 3.0.3 establishes the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirements.
The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown CONDITION when plant Operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or componts being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower CONDITIONS of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applies.
If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION
requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required actions.
- .e
3/4.0 APPLICABILITY
BASES (Con't)
The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in COLD SHUTDOWN when a shutdown is required during POWER operation. If the plant is in a lower CONDITION of operation when a shutdown is required, the time limit for reaching the next lower CONDITION of operation applies.
However, if a lower CONDITION of operation is reached In less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other OPERATIONAL
CONDITION, is not reduced. For example, if STARTUP is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the time allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total time to reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
Therefore, if remedial measures are completed that would permit a return to POWER operation, a penalty is not incurred by having to reach a lower CONDITION of operation in less than the total time allowed.
The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into an OPERATIONAL CONDITION or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher CONDITION of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower CONDITION of operation. A
The shutdown requirements of Specification 3.0.3 do not apply in CONDITIONS 4 and 5, because the ACTION requirements of Individual specifications define the remedial measures to be taken.
Specification 3.0.4 establishes limitations on a change in OPERATIONAL
CONDITIONS when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher CONDITION of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION
requirements if a change in CONDITIONS were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher CONDITIONS of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION
requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a change in OPERATIONAL CONDITIONS. Therefore, in this case, entry into an OPERATIONAL
CONDITION or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.
- _.... - _* _ . _* . A._ -*_ .. -.. ..._
- . nv f vn1o ir lant *1 ?V
3/4.0 APPLICABILITY
BASES (Con't)
When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower CONDITION of operation.
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,
OSurveillance 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 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 facility is is 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 conditions under which the specified time interval for Surveillance Requirements may be extended. Item a. 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. Item b.
limits the use of the provisions of item a. to ensure that it is not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are 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. These provisions are 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 failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure BWR STS B 3/4.0-4
1 R 6
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3/4.0 APPLICABILITY
BASES (Con't)
to meet the OPERABILITY requirements for a 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 although still meeting the Surveillance Requirements. 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 4.0.3. 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 4.0.2, 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 4.0.2 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.
If 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 /> or a shutdown is required to comply with ACTION requirements, e.g.,
Specification 3.0.3., a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown would be required to comply with ACTION requirements or before other remedial measures would be required that may preclude the completion of a surveillance.
The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance.
This provision also provides a time limit for the completion of Surveillance Requirements that become applicable as a consequence of CONDITION changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification
4.0.4 is allowed. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION
requirements are applicable at the time that the surveillance is terminated.
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 have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.
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3/4.0 APPLICABILITY
BASES (Con't)
Specification 4.0.4 establishes the requirement that all applicable surveillances ust be met before entry into an OPERATIONAL CONDITION 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 an OPERATIONAL
CONDITION or other specified condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL CONDITIONS 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 assume 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 would delay placing the facility in a lower CONDITION of operation.
Specification 4.0.5 establishes the requirement that inservice inspection of ASIE Code Class l, 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 versiHon 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 writ4ng 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 CONDITION
or other specified condition takes precedence over the ASME Boiler and Pressure Vessel Code provision that 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, which is not capable of performing its specified function, is declared Inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision that allows a valve to be Incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.
J _ .
LIST @. RECENTLY ISSUED GENERIC k.ITERS
Generic Date of Letter No. Subject Issuance I.ssued To GL 87-08 IMPLEMENTATION OF 10 CFR 73.55 05/11/87 ALL POWER
MISCELLANEOUS AMENDMENTS AND REACTOR
SEARCH REQUIREMENTS LICENSEES
GL 87-07 INFORMATION TRANSMITTAL OF 03/19/87 ALL FACILITY
FINAL RULEMAKING FOR REVISIONS LICENSEES
TO OPERATOR LICENSING-IOCFR55 AND CONFORMING AMENDMENTS
GL 87-06 TESTING OF PRESSURE ISOLATION 03/13/87 ALL OPERATING
VALVES REACTOR
LICENSEES
GL 87-05 REQUEST FOR ADDITIONAL 03/12/87 LICENSEES OF
INFORMATION-ASSESSMENT OF OR'S,
LICENSEE MEASURES TO MITIGATE APPLICANTS FOR
AND/OR IDENTIFY POTENTIAL OL'S, AND
DEGRADATION MKI HOLDERS OF
MARK I
CONTAINMENTS
GL 87-04 TEMPORARY EXEMPTION FROM 03/06/87 ALL POWER
PROVISIONS OF THE FBI CRIMINAL REACTOR
HISTORY RULE-FOR TEMPORARY LICENCES
WORKERS
GL 87-03 VERIFICATION OF SEISMIC 02/26/87 ALL LICENSEES
ADEQUACY OF MECHANICAL AND NOT SUBJECT TO
ELECTRICAL EQUIPTMENT IN USI A-46 OPERATING REACTORS, USI A-46 REQUIREMENTS
GL 87-02 VERIFICATION OF SEISMIC 02/19/87 ALL HOLDERS OF
ADEQUACY OF MECHANICAL AND OPERATING
ELECTRICAL EQUIPMENT IN LICENSES NOT
OPERATING REACTORS (USI A-46) REVIEWED TO
CURRENT
LICENSING
CRITERIA ON
SEISMIC
QUALIFICATION
OF EQUIPMENT
GL 87-01 PUBLIC AVAILABILITY OF THE NRC 01/08/87 ALL POWER
OPERATOR LICENSING EXAMINATION REACTOR
QUESTION BANK LICENSEES AND
APPLICANTS FOR
AN OPERATING
LICENSE
-3- surveillance interval. Specification 4.0.4 should not be used to prevent passage through or to operational modes as required to comply with Action Requirements because to do so: (a)would increase the potential for a plant upset; and (b)would challenge safety systems. Also, certain surveillances should be allowed to be performed during a shutdown to comply with Action Requirements. Along with the modification of Specification 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of Action Requirements, Specification 4.0.4 has been clarified to allow passage through or to operational modes as required to comply with Action Requirements.
A second conflict could arise because, when Surveillance Requirements can only be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed. However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore, to avoid any conflict between Specifications
4.0.3 and 4.0.4, the staff wants to make clear: (a)that it is not the intent of Specification 4.0.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to Specification 4.0.4; and (b)that the delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability of Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of allowance of any exception to Specification 4.0.4.
If you have any questions on this matter, please contact your project manager.
Sincerely, Frank J. Miraglia, Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
As stated (SECTIONS 3.0 AND 4.0)
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