ML070320178
| ML070320178 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/31/2007 |
| From: | Gerald Bichof Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 07-0069 | |
| Download: ML070320178 (30) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY
- RICHMOND, VIRGINIA 2326 1 January 31, 2007 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Serial No.
07-0069 NL&OS/GDM RO Docket Nos.
50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SlJRRY POWER STATION UNITS I AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE MISSED SURVEILLANCE REQUIREMENTS Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests arnendments, in the form of changes to the Technical Specifications (TS) to Facility Olperating License Numbers DPR-32 and DPR-37 for Surry Power Station Units I and 2, respectively. The proposed change revises the TS surveillance requirements (SR) for addressing a missed surveillance and is consistent with the NRC-approved Revision 6 of lndustryrrechnical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-358, Missed Sun/eillance Requirements (TSTF-358). The availability of this TS improvement was published in the Federal Register on September 24, 2001, as part of the NRC's Consolidated Line Item Improvement Process (CLIIP). To facilitate implementation of TSTF-358 into the Surry Units 1 and 2 TS, changes to SRs 4.0.1 and 4.0.3 are also being proposed for consistency with their corresponding improved STS (NUREG-1431, Revision 3, Standard Technical Specifications Westinghouse Plants) Sections 3.0.1 and 3.0.3, respectively.
A description and assessment of the proposed amendment is provided in Attachment 1.
The marked-up and typed proposed TS pages are provided in Attachments 2 and 3, respectively. The associated Bases changes are provided for information only and will be implemented in accordance with the TS Bases Control Program and 10 CFR 50.59.
The proposed amendment has been reviewed and approved by the Station Nuclear Safety and Operating Committee. We have also evaluated the proposed TS revisions that are included in the License Amendment Request to facilitate implementation of the TSTF-358 changes and have determined that these additional revisions do not involve a significant hazards consideration as defined in 10CFR50.92. We have also determined that operation with the proposed additional revisions will not result in any significant increase in the amount of effluents that may be released offsite and no significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion as set forth in 1 OCFR51.22(~)(9). Pursuant to IOCFR51.22(b), no environmental impact statement or
Serial No. 07-0069 Docket Nos. 50-2801281 Page 2 of 4 er~vironmental assessment is needed in connection with the approval of the proposed ch~ange. The bases for these two determinations are provided in Attachment 1.
Dominion requests a 30-day implementation period following NRC approval of the requested license amendments.
If you should have any questions regarding this submittal, please contact Mr. Gary D. Miller at (804) 273-2771.
Very truly yours,
/
Glerald T. Bischof Vice President - Nuclear Engineering Attachments:
- 1. Description and Assessment
- 2. Proposed Technical Specifications and Bases Pages (Mark-Up)
- 3. Proposed Technical Specifications and Bases Pages (Typed)
- 4. List of Commitments
Serial No. 07-0069 Docket Nos. 50-2801281 Page 3 of 4 cc:
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. N. P. Garrett NRC Senior Resident Inspector Surry Power Station Mr. S. P. Lingam NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852 Mr. L. N. Olshan NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11 555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, Virginia 2321 8
Serial No. 07-0069 Docket Nos. 50-2801281 Page 4 of 4 COMMONWEALTH OF VIRGINIA
)
)
COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this. ?/ ST day of
,2007.
My Commission Expires:
Notary Public (SEAL)
Serial No. 07-0069 Docket Nos. 50-2801281 Description and Assessment Virginia Electric and Power Company (Dominion)
Surry Power Station Units 1 and 2
Serial No. 07-0069 Docket Nos. 50-2801281 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
Virginia Electric and Power Company (Dominion) is proposing a license amendment that would revise the Surry Units 1 and 2 Technical Specifications (TS) requirements for addressing missed surveillances in Surveillance Requirement (SR) 4.0.3. The proposed changes are consistent with the Nuclear Regulatory Commission (NRC) approved lndustry/Technical Specification Task Force (TSTF) Standard Technical Specifications (SITS) change TSTF-358, Revision 6, Missed Surveillance Requirements (TSTF-358).
The availability of this TS improvement was published in the Federal Register on September 24, 2001, as part of the NRC's Consolidated Line Item Improvement Process (CLIIP). This license amendment request has been prepared in accordance with the NIIC1s CLllP and pursuant to the requirements of 10 CFR 50.90.
To facilitate implementation of TSTF-358 into the Surry TS, SRs 4.0.1 and 4.0.3 and their associated Bases require revision for consistency with their corresponding irr~
proved STS [NU REG-1 43 1, Rev. 3, Standard Technical Specifications Westinghouse Pl'ants] Sections 3.0.1 and 3.0.3, respectively, to address how a surveillance is met and to specify the actions required for a missed surveillance.
A TS Bases Control Program, required for implementation of TSTF-358, was previously inlcorporated into the Surry TS by License Amendments 2431242 dated July 15, 2005.
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation Dominion has reviewed the safety evaluation dated June 14, 2001, published as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-358 provided in Federal Register Notices, Vol. 66, Nos. 115 and 189 dated June 14 and September 28, 2001, respectively. Dominion concludes that the justifications presented in the TSTF proposal arid the safety evaluation prepared by the NRC staff are applicable to Surry Power Station, Units 1 and 2. Incorporation of the proposed changes into the Surry Power S1:ation Units 1 and 2 TS are justified based on this generic application.
2.2 Optional Changes and Variations Dominion is not proposing any variations or deviations from the intent of the TS changes described in the TSTF-358, Revision 6, or the NRC staff's model safety evaluation dated June 14, 2001. However, to ensure consistent implementation of TSTF-358 with the justification and safety analysis provided, Dominion is also revising Surry TS SR 4.0.1 and SR 4.0.3 and their associated Bases for consistency with their Page 1 of 5
Serial No. 07-0069 Docket Nos. 50-2801281 corresponding improved STS Sections 3.0.1 and 3.0.3, respectively, to address how a surveillance is met and to specify the actions required for a missed surveillance. Minor variationsldeviations in the TS terminology used in NUREG-1431 and TSTF-358 are required because Surry Power Station's Units 1 and 2 TS are custom TS and the wording does not directly correspond to the improved STS and TSTF-358 wording in every instance. For example, the Surry TS do not use the improved STS terms MODE, Completion Times or Required Actions, rather they use the corresponding terms REACTOR OPERATION, Allowed Outage Times and Action Statements instead.
These and similar terminology variationsldeviations from TSTF-358 and STS SR 3.0.1 a~nd 3.0.3 wording are necessary to ensure that the language used in the proposed L~icense Amendment Request is consistent with the terminology used throughout Surry's custom TS. However, the minor variationsldeviations from the specific wording included in the NUREGICLIIP do not change the intent of the TS, Bases or CLIIP.
The terminology differences are summarized in Attachment A for your reference.
The variations/deviations in TS terminology are consistent with the wording used in similar License Amendment Requests submitted by Florida Power and Light (FP&L) on November 21, 2001 (MLO13320088), as supplemented on January 25, 2002 (FdL020290087) and August 15, 2002 (ML022330463), and Omaha Public Power Dlistrict on July 22, 2002 (ML022130581), as supplemented on October 8, 2002 (FdL022900058). The NRC approved the License Amendment Requests for these two licensees in letters dated November 4, 2002 (ML023080336) and January 16, 2003 (FdL030220153), respectively.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination Dlominion has reviewed the proposed no significant hazards consideration dletermination (NSHCD) published in the Federal Register Notice, Vol. 66, dated J~une 14, 2001 as part of the CLllP and has concluded that the proposed NSHCD is applicable to Surry Power Station Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
Dlominion has also evaluated whether a significant hazards consideration is involved by incorporating the wording of improved STS Surveillance Requirement (SR) 3.0.1 and SR 3.0.3, as specified in NUREG-1431, into Surry TS SR 4.0.1 and SR 4.0.3, respectively. This change has been made to the extent practical to facilitate the ir~corporation of lndustry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-358, Revision 6, regarding missed surveillance requirements. Based on this evaluation, Dominion has determined that no significant hazards consideration exists based on the following:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Page 2 of 5
Serial No. 07-0069 Docket Nos. 50-2801281 The proposed change to incorporate the requirements of improved STS SR 3.0.1 and SR 3.0.3 into corresponding Surry TS SR 4.0.1 and SR 4.0.3, respectively, does not affect the design or operation of the plant. The proposed change involves revising the existing Surry custom TS to be consistent with NUREG-1431, Revision 3, to facilitate the incorporation of TSTF-358 into the TS.
The proposed change involves no technical changes to the existing TS as it merely clarifies how SRs are met. As such, these changes are administrative in nature and do not affect initiators of analyzed events or assumed mitigation of accident or transient events. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change to incorporate the requirements of improved STS SR 3.0.1 and SR 3.0.3 into corresponding Surry TS SR 4.0.1 and SR 4.0.3, respectively, does not involve a physical alteration to the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change revises the existing Surry TS to be consistent with NUREG-1431, Revision 3, to clarify how SRs are met and facilitates the incorporation of TSTF-358 for addressing missed surveillances. As such, the proposed change will not impose any new or different requirements or eliminate any existing requirements. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
The proposed change to incorporate the requirements of improved STS SR 3.0.1 and SR 3.0.3 into corresponding Surry TS SR 4.0.1 and SR 4.0.3, respectively, does not affect plant operation or safety analysis assumptions in any way. The change provides additional clarification on how a surveillance is met and facilitates the incorporation of TSTF-358 for addressing missed surveillances.
The change is administrative in nature and does not affect the operation of safety-related systems, structures, or components. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
3,.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on September 24, 2001, for this TS improvement, plant-specific verifications were plerformed as follows:
Page 3 of 5
Serial No. 07-0069 Docket Nos. 50-2801281 As noted above, to facilitate implementation of TSTF-358, Dominion is also incorporating thle wording from the improved STS SR 3.0.1 and SR 3.0.3 and their associated Bases, into corresponding Surry TS SR 4.0.1 and SR 4.0.3, respectively, as well as the changes included in TSTF-358.
Furthermore, Dominion has established TS Bases for SR 4.0.3 which state that the use of the delay period established for SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of a missed surveillance.
The proposed revision will also include changes to the Bases for SR 4.0.3 that provide detail on how to implement the new requirements.
The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases state that a missed surveillance test is expected to be performed at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the 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.I 82, Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants. The missed surveillance should then be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that a missed surveillance for an important component should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the course of action. In addition, the Bases state that all missed surveillance tests will be placed in the licensee's corrective action program.
Fi~nally, the Surry TS currently include a TS Bases Control Program in TS 6.4.J that is consistent with Section 5.5 of the improved STS.
4,,0 ENVIRONMENTAL EVALUATION 4,,1 Incorporation of TSTF-358, Revision 6 Dominion has reviewed the environmental evaluation associated with TSTF-358 included in the model safety evaluation dated June 14, 2001, as part of the CLIIP.
Dominion has concluded that the staff's findings presented in that evaluation are applicable to Surry Power Station Units 1 and 2, and the evaluation is hereby incorporated by reference for this application.
Page 4 of 5
Serial No. 07-0069 Docket Nos. 50-2801281 4.2 Incorporation of Improved Standard Technical Specification Wording for Surry TS SR 4.0.1 and 4.0.3 Dominion has further determined that the revision of Surry TS SR 4.0.1 and SR 4.0.3 and their associated Bases to make them consistent with NUREG-1431, Revision 3, will not result in any significant increases in the amounts of any effluents that may be released offsite or any significant increases in individual or cumulative occupational radiation exposure. The proposed change is administrative in nature, and, as such, does not affect the operation of the plant. Therefore, the proposed change is eligible for categorical exclusion as set forth in 10 CFR 51.22(~)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change as the proposed administrative change will not result in an undue risk to the health and safety of the public.
Page 5 of 5
Serial No. 07-0069 Docket Nos. 50-2801281 Attachment A ITS Section SR 3.0.1 Bases Surry TS Section SR 4.0.3 SR 4.0.1 Bases Variation from ITS and/or the TSTF-358 Wording for Surrv Power Station Units I and 2 Custom TS The word MODES is changed to the term REACTOR OPERATION conditions since Surry TS do not use the MODE convention to describe reactor operation parameters or include it as a defined TS term.
The term Applicability for individual LCOs is changed to individual Limiting Conditions for Operation (LCO) since the TS term Applicability is not consistently used in the same manner in Surry TS as it is in STS.
The term Condition(s) must be entered is changed to action(s) must be taken since Surry TS use Action Statements as opposed to Conditions.
The word MODE(S) is changed to the term REACTOR OPERATION condition(s) since Surry does not use the MODE convention to describe reactor operation parameters or include it as a defined TS term.
The term Applicability for which the requirements of the LC0 apply is changed to individual Limiting Conditions for Operation (LCO) that apply since the TS term Applicability is not consistently used in the same manner in Surry TS as it is in STS.
The sentence at the end of the first paragraph of STS SR 3.0.1 Bases, which states, "Additionally, the definitions related to instrument testing (e.g.,
CHANNEL CALIBRATION) specify that these tests are performed by means of any series of sequential, overlapping, or total steps," is not included in the Surry TS SR 4.0.1 Bases since the Surry TS do not contain such wording in the instrument testing definitions contained in TS 1.O.
The terms Required Action(s) and ACTIONS are changed to Action Statements for consistency with Surry TS terminology.
Page 1 of 2
Serial No. 07-0069 Docket Nos. 50-2801281 SR 3.0.3 Bases SR 4.0.3 Bases The word Applicability is changed to individuai iCO in tne sixth paragraph, since the TS term Applicability is not consistently used in the same manner in Surry TS as it is in STS.
The high pressure safety injection example is not included since it is not applicable to Surry. The auxiliary feedwater turbine pump testing example is retained but revised slightly in consideration of the specific testing conditions included in Surry's TS (reference Surry TS 4.8.A.3.a.)
The term Required Actions is changed to Action Statement(s) for consistency with Surry TS terminology.
The terms MODE 1 and MODE have been changed to POWER OPERATION and REACTOR OPERATION condition, respectively, since Surry TS do not use the MODE convention to describe reactor operation parameters or include MODE 1 or MODE as defined terms.
The terms Completion Times of the Required Actions and Completion Time of the ACTIONS have been changed to Allowed Outage Time(s) of the Action Statements for consistency with Surry TS terminology.
Page 2 of 2
Serial No. 07-0069 Docket Nos. 50-2801281 Proposed Technical Specifications and Bases Panes (Mark-up1 Virginia Electric and Power Company (Dominion)
Surry Power Station Units 1 and 2
4.0 SURVEILLANCE REOUIREMENTS 4.0.2 Surveillance requirement specified time intervals may be adjusted plus or minus 25 percent to accommodate normal test schedules.
4.0.4 Entry into an operational condition shall not be made unless the surveillance K requirement(s) associated with a Limiting Condition of Operation has been ii performed within the stated surveillance interval or as otherwise specified. This V provision shall not prevent passage through or to operational conditions as required to comply with Action Statement requirements.
\\
Amendment NOS. -Hhd+W
4.0.2 The provisions of this specification provide allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance interval.
These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance value and permits
- 7--- --
the performance of more frequent surveillance activities.
w establishes the failure to perform a Surveillance
'\\/
within the allowed sur eillance interval, defined by the provisions of P
( Surveillance Requirements have not been complete@ithin the allowed I
( surveillance interval and that the time limits of the Action Statement requirements I" Amendment Nos. 3&aiwW&
TS 4.0-3 1 r
{'is identified that a surveillance has not been performed and not at the time of the surveillance Action Statement 4.0.3.
Action Statement requirements are less ed to comply with Action Statement 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowance is ents that have not been permit the completion of a o comply with Action Statement preclude completion of a s consideration for plant in completing the required surveillance. This /'
Amendment Nos. &%md+&-
provision also provides a time limit for the completion of surveillance terminated.
apply. However, the surveillance re inoperable equipment has been restored to OPERABLE status.
p d
ek k 4.0.4 This specification establishes the requirement that all applicable surveillances must be met before entry into an operational condition 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 condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in operational conditions associated with plant shutdown as well as startup.
Amendment Nos. 24hxxW&
INSERT I - Completelv replaces SR 4.0.1 Surveillance Requirements (SRs) shall be met during the REACTOR OPERATION conditions or other specified conditions in the individual Limiting Conditions for Operation (LCO), unless otherwise stated in the SR. 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 LC0 except as provided in SR 4.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
INSERT 2 - Completelv replaces existin~ SR 4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LC0 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 LC0 must immediately be declared not met, and the applicable action(s) must be taken.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LC0 must immediately be declared not met, and the applicable action(s) must be taken.
INSERT 3 - Completelv replaces SR 4.0.1 Bases Surveillance Requirement (SR) 4.0.1 establishes the requirement that SRs must be met during the REACTOR OPERATION conditions or other specified conditions in the individual Limiting Conditions for Operation (LCO) that apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the operability of systems and components, and that variables are within specified limits.
Failure to meet a Surveillance within the specified frequency, in accordance with SR 4.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified frequency.
Systems and components are assumed to be OPERABLE when the associated SRs 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 SRs; or
- b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.
Surveillances do not have to be performed when the unit is in a REACTOR OPERATION condition or other specified condition for which the requirements of the associated LC0 are not applicable, unless otherwise specified. The SRs associated with a test exception are only applicable when the test exception is used as an allowable exception to the requirements of a Specification.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given REACTOR OPERATION condition or other specified condition.
Surveillances, including Surveillances invoked by Action Statements, do not have to be performed on inoperable equipment because the Action Statements define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 4.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current REACTOR OPERATION condition or other specified conditions in the individual LC0 due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a REACTOR OPERATION condition or other specified condition where other necessary post maintenance tests can be completed.
An example of this process is Auxiliary Feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures that cannot be obtained until the unit is at HOT SHUTDOWN conditions. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
INSERT 4 - Completelv replaces exist in^ Bases for SR 4.0.3 SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater, applies from the point in time that
it is discovered that the Surveillance has not been performed in accordance with SR 4.0.2, and not at the time that the specified Surveillance 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 the Action Statement(s) or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering POWER OPERATION after each fuel loading, or in accordance with 113 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 4.0.3 allows for the full delay period of up to the specified frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of REACTOR OPERATION condition changes imposed by Action Statements.
Failure to comply with the specified frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.
While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity.
The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1..182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed
Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.
If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Alllowed Outage Time(s) of the Action Statement(s) for the applicable LC0 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 Allowed Outage Time(s) of the Action Statement(s) for the applicable LC0 conditions begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time(s) of the Action Statement(s), restores compliance with SR 4.0.1
Serial No. 07-0069 Docket Nos. 50-2801281 Proposed Technical Specifications and Bases Pacles (Typed)
Virginia Electric and Power Company (Dominion)
Surry Power Station Units 1 and 2
Serial No. 07-0069
+
Docket Nos. 50-2801281 TABULATION OF CHANGES License Nos. DPR-32 & 37 / Docket Nos. 50-280 & 281 Slummary of Change:
The proposed change to the Surry Power Station Units 1 and 2 Technical Specifications and Bases incorporates lndustryrrechnical Specification Task Force (TSTF) Standard Technical Specifications change TSTF-358, Revision 6, Missed Sun/eillance Requirements, and revises TS SRs 4.0.1 and 4.0.3 and their associated Bases for consistency with improved Standard Technical Specifications (NUREG-1431, Rev. 3) and to facilitate incorporation of TSTF-358.
DATED SUBSTITUTE
4.0 SURVEILLANCE REOUIREMENTS 4.0.1 Surveillance Requirements (SRs) shall be met during the REACTOR OPERATION conditions or other specified conditions in the individual Limiting Conditions for Operation (LCO), unless otherwise stated in the SR. 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 LC0 except as provided in SR 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
4.0.2 Surveillance requirement specified time intervals may be adjusted plus or minus 25 percent to accommodate normal test schedules.
4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LC0 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 L C 0 must immediately be declared not met, and the applicable action(s) must be taken.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LC0 must immediately be declared not met, and the applicable action(s) must be taken.
4.0.4 Entry into an operational 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 prevent passage through or to operational conditions as required to comply with Action Statement requirements.
Amendment Nos.
BASES 4.0.1 Surveillance Requirement (SR) 4.0.1 establishes the requirement that SRs must be met during the REACTOR OPERATION conditions or other specified conditions in the individual Limiting Conditions for Operation (LCO) that apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the operability of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified frequency, in accordance with SR 4.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the entire Surveillance is performed within the specified frequency.
Systems and components are assumed to be OPERABLE when the associated SRs 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 SRs; or
- b.
The requirements of the Surveillance(s) are known not to be met between re-quired Surveillance performances.
Surveillances do not have to be performed when the unit is in a REACTOR OPERATION condition or other specified condition for which the requirements of the associated LC0 are not applicable, unless otherwise specified. The SRs associated with a test exception are only applicable when the test exception is used as an allowable exception to the requirements of a Specification.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given REACTOR OPERATION condition or other specified condition.
Surveillances, including Surveillances invoked by Action Statements, do not have to be performed on inoperable equipment because the Action Statements define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 4.0.2, prior to returning equipment to OPERABLE status.
Amendment Nos.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current REACTOR OPERATION condition or other specified conditions in the individual LC0 due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a REACTOR OPERATION condition or other specified condition where other necessary post maintenance tests can be completed.
An example of this process is Auxiliary Feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures that cannot be obtained until the unit is at HOT SHUTDOWN conditions. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
The provisions of this specification provide allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance interval.
These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance value and permits the performance of more frequent surveillance activities.
SR4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 4.0.2, and not at the time that the specified Surveillance 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 the Action Statement(s) or other remedial measures that might preclude completion of the Surveillance.
Amendment Nos.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g.,
prior to entering POWER OPERATION after each he1 loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 4.0.3 allows for the full delay period of up to the specified frequency to perform the Surveillance.
However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of REACTOR OPERATION condition changes imposed by Action Statements.
Failure to comply with the specified frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use Amendment Nos.
quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.
If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Allowed Outage Time(s) of the Action Statement(s) for the applicable LC0 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 Allowed Outage Time(s) of the Action Statement(s) for the applicable LC0 conditions begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time(s) of the Action Statement(s),
restores compliance with SR 4.0.1.
4.0.4 This specification establishes the requirement that all applicable surveillances must be met before entry into an operational condition 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 condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in operational 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.
Exceptions to Specification 4.0.4 allow performance of surveillance requirements associated with a Limiting Condition for Operation after entry into the applicable operational condition.
When a shutdown is required to comply with Action Statement requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower condition of operation.
Amendment Nos.
Serial No. 07-0069 Docket Nos. 50-2801281 List of Commitments Virginia Electric and Power Company (Dominion)
Surry Power Station Units I and 2
Serial No. 07-0069 Docket Nos. 50-2801281 LIST OF COMMITMENTS SURRY POWER STATION UNITS I AND 2 The following table identifies those actions committed to by Dominion in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct any questions regarding these commitments to Mr. Gary D. Miller at (804) 273-2771.
t Commitment Page 1 of 1 Due DateIEvent Dominion will establish the Technical Specifications Bases for SRs 4.0.1 and 4.0.3 as adopted with the applicable license amendment.
To be implemented with the amendment.