ML19316A744

Tech Spec Change Request 63 to Change Tech Specs 3/4 & B 3/4 Re Limiting Conditions for Operation & Surveillance Requirements

ML19316A744
Person / Time
Site:	Crystal River
Issue date:	05/21/1980
From:	FLORIDA POWER CORP.
To:
Shared Package
ML19316A741	List: ML19316A740 ML19316A744
References
TAC-43037, NUDOCS 8005270437
Download: ML19316A744 (9)

Text

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TECHNICAL SPECIFICATION CHANGE REQUEST NO. 63 (APPENDIX A)

Replace pages 3/4 0-1, 3/4 0-2, B 3/4 0-1 and B 3/4 0-2 with the attached revised pages 3/4 0-1, 3/4 0-2, B 3/4 0-1 and B 3/4 0-2.

Add new pages3/4 0-3 and B 3/4 0-4.

Proposed Changes On page 3/4 0-1, add "....until the reactor is placed in a Mode in which the specification is not applicable" to Specification 3.0.3.

On page 3/4 0-1, add new Specification 3.0.5 concerning Operabili-ty of systems in relation to normal and emergency power supplies.

On page B 3/4 0-1, add the second example concerning Specifica-tion 3.6.2.1 to be the basis of Specification 3.0.3.

On pages B 3/4 0-2 and B 3/4 0-3 add the basis for new Specifica-tion 3.0.5.

Reasons for Proposed Change The purpose of this Proposed Change, as stated in NRC correspon-dence to All Power Reactor Licensees, dated April 10, 1980, is to clarify any misunderstanding that may exist in regards to the use of the term OPERABLE as it applies to the single failure criterion for safety systems in power reactors. Specifically, this Proposed ,

Change adds clarification to actions required wh'en normal or emer- '

gency power supplies become inoperable.

Safety Analysis of Proposed Change Technical Specifications preserve the single failure criterion for systems that are relied upon in the safety analysis report by use ,

of Limiting Conditions for Operation (LCOs) that require all re- )

dundant components of safety related systems to be OPERABLE. When '

the required redundancy is not maintained, either due to equipment failure or maintenance outage, action is required within a speci-fied time to change the operating mode of the plant to place it in a safe condition. The specified time to take action is a tempo-rary relaxation of the single failure criterion which, consistent ,

with overall system reliability considerations, provides a limited l time to repair equipment or otherwise make it OPERABJ. It equip- .

ment can be returned to OPERABLE status within the specified time, 1 plant sSutdown is not required. l l

LCOs are specified for each safety related system in the plant, i and with few exceptions, the ACTION statements address single out-  !

ages of components, trains or subsystems. For any particular sys- I tem, the LC0 does not address multiple outages of redundant compo- I nents, nor does it address the effects of outages of any support systems, such as electrical power or cooling water, that are re-lied upon to maintain the OPERABILITY of the particular system.

8005270 4/N

Page Two This is because of the large number of combinations of these types of outages that are possible. Instead, Technical Specifications employ general specifications and an explicit definition of the term OPERABLE to encompass all such cases. These provisions have been formulated to assure that no set of equipment outages would be allowed to persist that would result in the facility being in an unprotected condition.

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3/4 LIMITING CONDITIONS FOR OPERATION AND_ SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification.

3.0.2 Adherence to the requirements of the Limiting Condition for Oper-ation and/or associated ACTION within the specified time interval shall constitute compliance with the specification. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.

3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in ex-cess of those addressed in the specification, the facility shall be placed in at least HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless either (1) corrective measures are com-pleted that permit operation under the permissible ACTION statements for the specified time interval at measured from initial discovery, or (2) until the reactor is placed in a Mode in which the specification is not ,

applicable. Exceptions to these requirements shall be stated in the in- 1 dividual specification.

3.0.4 Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Con-dition for Operation are met without mliance on provisions contained in the ACTION statements unless otherwise excepted. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION statements.

3.0.5 When a system, subsystem, train, component or device is deter-mined to be inoperable solely because its emergency power source is in-operable, or solely because its normai power source is inoperable per Specification 3.8.1.1, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Op-eration, provided: (1) its corresponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s), subsys-tem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and in at least COLD SHUTDOWN within the following 3G hours. This specification is not applicable in MODES 5 or 6.

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r APPLICABILITY SURVEILLANCE REQUIREMENTS .

4.0.1 Surveillance Requirements shall be applicable during the OPERA-TIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Sur-veillance 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 sur-veillance interval, and

b. A total maximum combined interval time for any 3 consecutive tests not to exceed 3.25 times the specified surveillance interval.

4.0.3 Performance of a Surveillance Requirenent within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated Actions statements unless otherwise required by the specification. Surveillance Require-ments do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified applicability conditions shall not be made unless the Surveillance Requirement (s) as-sociated with the Limiting Condition for Operation has been performed within the stated surveillance interval or as otherwise specified.

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. For the time period from issuance of the Facility Operating License to the start of facility commercial operation, inser- )

vice 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 1974 Edition, and Addenda through Summer 1975, except where specific written relief has been granted by the Commission.

b. For the time period following start of facility commercial op-eration, 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 Sec-tion XI of the ASME Boiler and Pressure Vessel Code and appli-cable Addenda as required by 10 CFR 50, Section 50.55a(g), ex- l cept where specific written relief has been granted by the l Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i). '

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APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements. The provisions of Specificiation 4.0.2 are not applicable to surveillance intervals associated with inservice inspection and testing activities required by Section XI of the above ASME Boiler and Pressure Vessel Code and applicable Addenda.

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3/4.0 APPLICABILITY BASES The specifications of this section provide the general requirements applicable to each of the Limiting Conditions for Operation and Surveil-lance Requirements within Section 3/4.

3.0.1 This specification defines the applicability of each specifi-cation in terms of defined OPERATIONAL MODES or other specified condi-tions and is provided to delineate specifically when each specification is applicable.

3.0.2 This specification defines those conditions necessary to con-stitute compliance with the terms of an individual Limiting Condition for Operation and associated ACTION requirement.

3.0.3 This specification delineates the ACTION to be taken for cir-cumstances not directly provided for in the ACTION statements and whose occurrence would violate the intent of the specification. For example, Specification 3.5.1 calls for each Reactor Coolant System core flooding tank to be OPERABLE and provides explicit ACTION require-ments when one tank is inoperable. Under the terms of Specification 3.0.3, if more than one tank is inoperable, the unit is required to be in at least HOT STANDBY within I hour and at least COLD SHUTDOWN in the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. As a further example, Specification 3.6.2.1 requires two Containment Spray Systems to be OPERABLE and provides explicit ACTION requirments if one spray system is inoperable. Under the terms of Specification 3.0.3, if both of the required Containment Spray Systems are inoperable, the unit is required to be in at least HOT STANDBY with-in I hour and in at least COLD SHUTDOWN in the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. It is as-sumed that the unit is brought to the required MODE within the required times by promptly initiating and carrying out the appropriate ACTION statement.

3.0.4 This specification provides that entry into an OPERATIONAL MODE or other specified applicability condition must be made with (a) the full complement of required systems, equipment or components OPERA-BLE and (b) all other parameters as specified in the Limiting Conditions for Operation being met without regard for allowable deviations and out of service provisions contained in the ACTION statements.

The intent of this provision is to insure that facility operation is not initiated with either required equipment or systems inoperable or other specified limits being exceeded.

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APPLICABILITY BASES Exceptions to this provision have been provided for a limited number of specifications when startup with inoperable equipment would not af-fect plant safety. These exceptions are stated in the ACTION statements of the appropriate specifications.

3.0.5 This specification delineates what additional conditions must be satisfied to permit operation to continue, consistent with the ACTION statements for power sources, when a normal or emergency power source is not OPERABLE. It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable

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and a systen, subsystem, train, component or device in another division 1s inoperable for another reason.

The provisions of this specification permit the ACTION statements asso-ciated with individual systems, st bsystems, trains, components, or de-vices to be consistent with the AC? ION statements of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individ-ual ACTION statements for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoper-ability of its normal or emergency power source.

For example, Specification 3.8.1.1 requires in part that two emergency diesel generators be OPERABLE. The ACTION statement provides for a 77-hour out-of-service time when one emergency diesel generator is not 0.<ERABLE. If the definition of OPERABLE were applied without considera-tion of Specification 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable emergency power source would also be inoperable. This would dictate invoking the applicable ACTION state-ments for each of the applicable Limiting Corditions for Operation.

However, the provisions of Specification 3.0.5 permit the time limits for continued operation to be consistent with the ACTION statement for the inoperable emergency diesel generator instead, provided the other specified conditions are satisfied. In this case, this would mean that the corresponding normal power source must be OPERABLE, or otherwise satisfy Specification 3.0.5 (i.e., be capable of performing their design function and have at least one normal or one emergency power source OPERABLE). If they are not satisfied, shutdown is required in accord-ance with this specification.

As a further example, Specification 3.8.1.1 requires in part that two physically independent circuits between the offsite transmission network and the onsite Class IE distribution systen be OPERABLE. The ACTION statement provides a 24-hour out-of-service time when both required off-site circuits are not OPERABLE. If the definition of OPERABLE were ap-plied without consideration of Specification 3.0.5, all systems, CRYSTAL RIVER - UNIT 3 B 3/4 0-2

O APPLICABILITY BASES subsystems, trains, components and devices supplied by the inoperable normal power sources, both of the offsite circuits, would also be inop-erable. This would dictate invoking the applicable ACTION statements for each of the applicable LOCs. However, the provisions of Specifica-tion 3.0.5 permit the time limits for continued operation to be consis-tent with the ACTION statement for the inoperable normal power sou ;es instead, provided the other specified conditions are satisfied. In this case, this woald mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE, or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design func-tions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, shutdown is re-quired in accorance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the in-dividual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

4.0.1 This specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable. Provisions fc' additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

4.0.2 The provisions of this specificiation provide allowable tol-erances for performing surveillance activities beyond those specificd in the nominal surveillance interval. These tolerances are necessary to provide operational fleribility because of scheduling and perrormance considerations.

The tolerance values, taken either individually or consecatively over 3 test intervals, are sufficiently nastrictive to ensure *. hat the reliability associated with the surveillance activity is not signifi-cantly degraded beyond that obtained from the nominal specified interval.

4.0.3 The provisions of this specification set forth the criteria for determination of compliance with the OPERABILITY requiremcats of the l Limiting Conditions for Operations. Under this criteria, equipment, l systems or components are assumed to be OPERABLE if the associated sur-veillance activities have been satisfactorily performed within the CRYSTAL RIVER - UNIT 3 8 3/4 0-3

i s l APPLICABILITY BASES specified time interval. Nothing in this provision is to be construed defining equipment, systems or components OPERABLE, when such items found or known to be inoperable although still meeting the Requirements.

4.0.4 This specification ensures that the surveillance activities associated with a Limiting Condition for Operation have been performed within the specified time interval prior to entry into an OPERATIONAL MODE or other applicable condition. The intent of this provision is to ensure that surveillance activities have been satisfactorily demonstrat-ed on a current basis as required to meet the OPERABILITY requirements of the Limiting Condition for Operation.

Under the terms of tnis specification, for example, during initial plant startup or following extended plant outages, the applicable surveillance activities must be performed within the stated surveillance interval prior to placing or returning the system or equipment into OPERABLE status, a

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