ML040400226

Tech Spec Pages for License Amendment 240, Extension of Delay Period as Result of Missed Surveillance

ML040400226
Person / Time
Site:	Oyster Creek
Issue date:	02/05/2004
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML040400229	List: ML040400226
References
TAC MC1453
Download: ML040400226 (5)

Text

TABLE OF CONTENTS (cont'd)

Section 5 Design Features Page 5.1 Site 5.1-1 5.2 Containment 5.2-1 5.3 Auxiliary Equipment 5.3-1 Section 6 Administrative Controls 6.1 Responsibility 6-1 6.2 Organization 6-1 6.3 Facility Staff Qualifications 6-2a 6.4 DELETED 6-3 6.5 Review and Audit 6-3 6-6 Reportable Event Action 6-9 6-7 Safety Limit Violation 6-9 6-8 Procedures and Programs 6-10 6-9 Reporting Requirements 6-13 6-10 Record Retention 6-17 6-11 Radiation Protection Program 6-18 6-12 (Deleted) 6-18 6-13 High Radiation Area 6-18 6-14 Environmental Qualification 6-19*

6-15 Integrity of Systems Outside Containment 6-19 6-16 Iodine Monitoring 6-19 6-17 Post Accident Sampling 6-20 6-18 Process Control Plan 6-20 6-19 Offsite Dose Calculation Manual 6-20 6-20 DELETED 6-20 6-21 Technical Specification (TS) Bases Control Program 6-21

• Issued by NRC Order dated 10-24-80 OYSTER CREEK iii Amendment No.: 94, 97,r9, 1-0 115, 131, 166, 136 232, 240

Section 4 Surveillance Requirements 4.0 Surveillance Requirement Applicability 4.0.1 Surveillance requirements shall be met during the modes or other specified conditions in the applicability for individual LCOs, unless otherwise stated in the surveillance requirements. Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performances of the surveillance, shall be failure to meet the LCO. Failure to perform a surveillance within the specified frequency shall be failure to meet the LCO except as provided in 4.0.2. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

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

If the surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable condition(s) must be entered.

When the surveillance is performed within the delay period and the surveillance is not met, the LCO must immediately be declared not met, and the applicable condition(s) must be entered.

BASES: Surveillance Requirement 4.0.1 establishes the requirement that surveillance requirements must be met during the modes or other specified conditions in the applicability for which the requirements of the LCO apply, unless otherwise specified in the individual surveillance requirements. 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 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:

a. The systems or components are known to be inoperable, although still meeting the surveillance requirements; or Oyster Creek 4.0-1 Amendment No. 4-5, 240

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 unit is in a mode or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified.

Surveillances, including surveillances invoked by required 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 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. Post maintenance testing may not be possible in the current mode or other specified conditions in the applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed tobbe incapable of performing its function. This will allow operation to proceed to a mode or other specified condition where other necessary post maintenance tests can be completed.

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

This delay period provides adequate time to complete surveillances that have been missed. This delay period permits the completion of a surveillance before complying with required actions or other remedial measures that might preclude completion of the surveillance.

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

Oyster Creek 4.0-2 Amendment No. 4-I, 240

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 power operation 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, Surveillance Requirement 4.0.2 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. Surveillance requirement 4.0.2 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 surveillance frequencies is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4.0.2 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified frequency is provided to perform the missed surveillance, it is expected that the missed surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the surveillance as well as any plant configuration changes required or shutting the plant down to perform the surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65 (a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management 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 evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed surveillances will be placed in the licensee's Corrective Action Program.

If a surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the completion times of the required actions for the applicable LCO conditions begin immediately upon expiration of the delay period. If a surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the completion times of the required actions for the applicable LCO conditions begin immediately upon the failure of the surveillance.

Completion of the surveillance within the delay period allowed by this specification, or within the completion time of the actions, restores compliance with Surveillance Requirement 4.0.1.

Oyster Creek 4.0-3 Amendment No. 48-5, 240

6.20 MAJOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS DELETED 6.21 Technical Specifications (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. Licensees may make changes to 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 (UFSAR) or Bases that requires NRC approval pursuant to 10 CFR 50.59.

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

d. Proposed changes that meet the criteria of Specification 6.21.b.1 or 6.21.b.2 above shall be reviewed and approved by the NRC prior to implementation. 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)

OYSTER CREEK 6.21 Amendment No. 108,166 49 4 240