ML19332C983

Proposed Tech Specs,Removing 3.25 Limit on Extending Surveillance Intervals from Tech Specs 4.0.2, Surveillance Requirements & Revising Bases Using Guidance Provided in Generic Ltr 89-14

ML19332C983
Person / Time
Site:	Summer
Issue date:	11/20/1989
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML19332C980	List: ML19332C979 ML19332C983
References
GL-89-14, NUDOCS 8911290254
Download: ML19332C983 (10)

Text

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1 MARKED UP TECHNICAL SPECIFICATION PAGES

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' Pace' Specification Chanae Description

-3/40-2 4.0.2," Surveillance ' Deletes item "b" which is the Requirements" 3.25 limit on extending surveillance intervals 83/402 Basis 4.0.2, " Applicability" Revisesthe Bases using .

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guidance provided in Generic Letter 89-14 ,

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& Attachment I to Document Control Desk Letter.

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' November 20, 1989 '

Y, 'Page"2 off3-APPLICABILITY SURVEILLANCE REQUIREMENTS

4. 0. 11 Surveillance Requirements shall be< applicable during the OPERATIO

' MODES or.other conditions specified for individual Limiting Conditions for Operation'unless otherwise stated in an individual Surveillance Requirem .

4.0.2

.m Each S. _ _,urveillance Requirement shall be m SunvEttt AHtE. INTERVAL v2 T% A MAMMuM'fied ALLrformed E-IMYGMIoVh2 WTYo%caED 25 PrRcENT OF THE "LPEOPLED VAL- SuM imum interva , allowable extension not to exceed z u tne of surveii'n,u I

b. The combined imeli rv co intervals sha im cutive surveillance-inter"". ~ .

ified surveillance l

~4.0.'3 i Failure to perform a Surveillance Requirement within the allowed -

surveillance interval, defined by Specification 4.0.2, shall constitute i' noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation.

time.it is identified that a Surveillance' Requirement has no pe rf ortaed.

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 MODE or other specified condition shall not Condition for~0peration have been performed within interval or. as otherwise specified.

This provision shall not prevent passage ,

through or to OPERATIONAL MODES as required to comply with ACTION re .

4.0.5 Code Class 1, 2 and 3 components shall be applicable as fo 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 a 10 CFR 50. Section 50.55a(g), pplicable Addenda as required by except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, ,

Section 50.55a(g)(6)(i). 1 1

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

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l. SUMMER - UNIT 1 3/4 0-2 Amendment No. 81 j

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APPOCABILITY

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- 4,0.1 This specification provides that surveillance activities necessary i

to insure the Limiting Conditions for Operation are met and will be performed lduring the OPERATIONAL MODES or other conditions for which the Limiting Conditions; for. Operation are applicable.

Provisions for additional surveil- 1 lance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Require-

'ments.

Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being-utilized as an exception to

_an ind_ividual specification, for perform The provisions of this specification provide allowable t nces urveillance activities beyond those specified i e nominal surveillance 'nte flexibility because o These tolerances are necessary to vide operational duling and performance c erations. The phrase d

"atleast"associateq a q 'llan r r mas not negate this allowable tolerance v r f perm t. for anc< of more frequent F+ surveillance activiti s. EB e

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-ga The tolerance va

m 3 test intervals has d eer ividu 1 onsecutively ova-7 sufficiently restrictive to ensure the reliabliity l

associated the surveillance activity is not significantly that aded beyond ned from the nominal specified interval.

4.0.3 This specification 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 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 -

4; .has not been performed and not at the time that the allowed surveillance 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 surveil-lance interval, defined by the provisions of Specification 4.0.2, was a viola-tion of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action. Further, the failure to perform a surveil-lance within the provisions of Specification 4.0.2 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the

requiremer's of 10 CFR 50.73(a)(2)(1)(B) because it is a cundition prohibited by the plant's Technical Specifications.

SUMMER - UNIT 1 B 3/4 0-2 Amendment No. 81

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INSERT 1 4.0.2 Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended, it i 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 condecting the surveillance; e.g. transient conditions or other i ongoing surveillance or maintenance activities. ,it also provides

' flexibility to accomodate the length of a fuel cycle for i surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not

, intended that:this provision be used repeatedly as a convenience to-extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outage!,.

The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of

• any particular' surveillance being performed is the verification of conformance=with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained.from the specified surveillance interval.

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ATTACHMENT 2

- SAFETY EVALUATION i

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SAFETY EVALUATION FOR  ;

VIRGIL C. SUMMER NUCLEAR STATION

- Description of Amendment Request:

Technical Specification 4.0.2 " Surveillance Requirements." provides the q allowable tolerances for extending surveillance intervals beyond those  !

specified in the nominal Surveillance Requirements. Currently. Specification 1

,' 4.0.2 requires that each surveillance activity be performed within the a specified time interval with: i (a); A maximum allowable extension not to exceed 25% of -I the surveillance interval, and (b) The combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.

The purpose of the 25-percent extension is to aid in the scheduling of surveillance activities and to permit surveillances to be postponed when  ;

plant conditions are not suitable for conducting a surveillance. The 3.25 I limit was designed to prohibit routine use of the 25-percent interval extension. ,

This'amendmenteliminatesrestriction(b)basedontheNRCStaffconclusion in Generic Letter 89-14 that the removal of the 3.25 limit results in a greater benefit to safety than limiting the use of the 25-percent allowance -

to extend' surveillance intervals.

SCE&G is requesting this revision because it will offer VCSNS more flexibility in using the Specification for extending surveillance intervals and will also reduce the administrative burden associated with its use. ,

SCE&G agrees with the NRC conclusion that this change will have a positive effect on safety.

Safety Evaluation:

Technical Specification 4.0.2 establishes the limit for which the specified time irterval for Surveillance Requirements may be extended. The limitation -

of Specification 4.0.2 is based on engineering judgement and the recognition that-the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This restriction is sufficient to ensure that the reliability associated with the surveillance activities is not significantly degraded beyond that obtained from the nominal surveillance interval. )

On August 21, 1989, the NRC issued Generic Letter 89-14 which provides guidance for the revision of Technical Specification 4.0.2. In this letter the Staff points out that even though the 25-percent extension is usually

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Attachment 2 to Document Control Desh Letter November 20, 1989 Page 2 of 2 sufficient to accommodate normal variations in fuel cycle lengths, numerous requests have been granted for one-time exceptions to the 3.25 limit. These requests were granted because the risk to safety from allowing exceptions to the limit is low in contrast to the alternative of a forced shutdown to perform these surveillances.

The Letter also discusses the safety benefit derived from the 25-percent i extension for surveillances that are performed on a routine basis during '

plant operation. When plant conditions are not suitable for performing  ;

surveillances, extending the interval results in a significant benefit to '

safety. In such cases, allowing the use of the 25-percent extension results in a greater benefit to safety than any benefit derived by limiting three -

consecutive surveillance intervals to the 3.25 limit.  ;

Based on these considerations, the Staff concluded that the removal of the 3.25 limit from Specification 4.0.2 results in a greater benefit to safety than limiting the use of the 25-percent allowance to extend surveillance '

intervals. SCE&G agrees with the conclusion and is using Generic Letter 89-14 as the basis for this Technical Specification change request. '

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' Attachment 3 t) Docum:nt COntr;l Desk L;tter November 20,1989 ATTACHMENT 3 NO SIGNIFICANT HAZARDS EVALUATION P

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l Attachment 3 to Document Control Desk Letter I November 20, 1989  !

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$1GNIFICANT HAZARDS EVALVATION FQ3  :

VIRGIL C. SUMMER NUCLEAR STATION _

Description of Amendment Request:

Technical Specification 4.0.2, " Surveillance Requiremer<ts " provides the j o allowable tolerances for extending surveillance intervals beyond those -

specified in the nominal Surveillance Requirements. Currently, Specification 4.0.2 requires that each surveillance activity be performed within the i specified time interval with:

(a) A maximum allowable extension not to exceed 25% of ,

the surveillance interval, and (b) The combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times ,

the specified surveillance interval.  ;

The purpose of the 25-percent extension is to aid in the scheduling of l surveillance activities and to permit surveillances to be postponed when '

plant conditions are not suitable for conducting a surveillance. The 3.25 '

limit was designed to prohibit routine use of the 25-percent interval extension.

This amendment eliminates restriction (b) based on the NRC Staff conclusion that the removal of the 3.25 limit results in a greater benefit to safety than limiting.the use of the 25-percent allowance to extend surveillance  ;

intervals. l SCE&G is requesting this revision because it will offer VCSNS more flexibility in using the Specification for extending surveillance intervals and will also reduce the administrative burden associated with its use.

Also, SCELG agrees with the NRC conclusion that this change will have a ,

positive effect on safety.

i The proposed amendment has been reviewed and determined not to involve a significant hazards consideration for the following reasons:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The c

change simply removes an unnecessary restriction on surveillance requirements and does not, therefore, affect the cons?quences of any of the previously evaluated accidents.

The 25-percent limitation is based on engineering judgement and the recognition that the most probable result of any surveillance is the verification that Surveillance Requirements are being met. This restriction is sufficient to ensure that the reliability associated with the surveillance activities is not significantly degraded beyond that obtained from the nominal surveillance interval. This revision, s

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therefore, does not involve a significant increase in the probability of ;

any previously evaluated accident. '

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. The revision does not involve a change in plant equipment or the manner in which plant equipment is operated. This change removes an existing undue restriction from the Specifications and does rot create any new accident scenarios.

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3. The proposed change does not result in a significant reduction in a margin of safety. The proposed change results in a benefit to safety becaut.e it will extend surveillance intervals when conditions are not i' favort.ble to perform the surveillence activity. Also, any safety risk incurred by allowing the deletion of the 3.25 limit for refueling surveillances is low compared to the risk incurred by having a forced shutdown to perform the surveillances.

With the 3.25 limit eliminated, the reliability ensured through surveillance activities will continue to be ensured through the 25-percen; limit on surveillance extensions. This limit, which is based on engineering judgement and the recognition that the most probable result -

of any performed surveillance is verification that the Surveillance Requirement is being met, ensures that reliability associated with surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval provided in the '

Technical Specifications.

For these reasons, the proposed change will not result in a significant reduction in a margin of safety.

Therefore, based on the above considerations, SCE&G has determined that this change does not involve a significant hazards consideration.

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