ML19351A495

Proposed Tech Spec 4.0.2 Re Surveillance Requirements

ML19351A495
Person / Time
Site:	Beaver Valley
Issue date:	12/12/1989
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML19351A489	List: ML19351A488 ML19351A493 ML19351A495
References
NUDOCS 8912190055
Download: ML19351A495 (12)

Text

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, . Revise :the Beaver Valley Unit No. 1 Technical Specifications as l follows:.  :

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,. . s. 1 3/4.0 APPLICABILITY 1

SURVEILLANCE REQUIREMENTS

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHOTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This specification is not applicable in MODES S or 6.

4.0.1 Surveillance Requirements chall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual .

Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the [

specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification'4.0.2, shall  !

constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a surveillance Requirement has not been performed. The ACTION requirements may be 'Jslayed 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 be made unless the Surveillance Requirement (s) associated with a Limiting condition for Operation has been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as .

follows:

a. Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as l . required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (1) .

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

BEAVER VALLEY - UNIT 1 3/4 0-2 PROPOSED WORDING l

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3/4.0 APPLICABILITY BASES (Con't) trains, components and devices in the other division must be s_

OPERABLE, or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABL2). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions muct also be OPERABLI. If these conditions .are not satisfied, action is required in accordance with this specification.

In MODES S or 6 Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting condition for Operation in these MODES must be adhered to:. '

Specification 4.0.1 throuah 4.0.5 establish the general requirements applicable to surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c) (3) :

" Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality  ;

of systems and components is maintained, that facility operation I will be within safety limits, and that the limiting conditions  ;

of operation will be met".  !

Soecification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this specification is to ensure that i

surveillances are performed to verify the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL l MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an j allowable exception to the requirements of a Specification. >

l Specification 4.0.2 establishes the limit for which the specified l time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activitics. It also provides flexibility to accomodate the length of a fuel cycle for surveillances that are j' 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 outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable BEAVER VALLEY - UNIT 1 B 3/4 0-5 PROPOSED  ;

4 3/4.0 APPLICABILITY BASES (Con't) 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.

Specification 4.0.3 establishes the failure to perform a Surveillance Requiremont within the allowed surveillance interval, def3ned 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 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 '

boon completed within the allowed surveillance interval and that the timo limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded.

Completion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3. However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action. Further, the failure to perform a surveillance within the provisions of Specification 4.0.2 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73 (a) (2) (1) (B) because it is a condition prohibited by the plant's Technical Specifications.

If the allowable outage time limits of the ACTION requirements are loss than 24 hours or a shutdown is required to comply with ACTION requirements, e.g., Specification 3.0.3, a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements.

This provides an adequato time limit to complete surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a timo limit for the completion of Surveillance Requirements that becomo applicable as a consequence of MODE changos imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If a surveillance is not completed within the 24-hour allowance, the BEAVER VALLEY - UNIT 1 B 3/4 0-6 PROPOSED

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ATTACHNENT A-2 .l

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Revise' the ' Beaver Valley' Unit No. 2 -Technical Specifications as -j

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L APPLICABILITY 9

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL H0 DES or other conditions specified for individual limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with)(

maximum allowable extension not to exceed 25% of the surveillance -

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,stfrvp fi,lanff 4.0.3 Failure to perform a Survelliance Requirement within the allowed surveil-lance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identi-fied that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Surveillance Requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL H0DE or other specified condition shall not be made unless the Surveillance Requirement (s) associated with a Limiting

, Condition for Operation has been performed within the stated surveillance

@ interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL M00E5 as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice ir.spection and testing"of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief i has been granted by the Commission pursuant to 10 CFR 50, Sec-tion 50.55a(g)(6)(i).

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications: i BEAVER VALLEY - UNIT 2 3/4 0-2 (WO$OSbh 1

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3/4.0 APPLICABILITY BASES _(ContinucJ) trains, components and devices in the other division must be OPERABLE, or like-wise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, i trains, components and devices in both divisions must also be OPERABLE. If i these conditions are not satisfied, action is required in accordance with this specification.

In H0 DES 5 or 6 Specification 3.0.5 is not applicable, and thus the indi-vidual ACTION statements for each applicable limiting Condition for Operation in these MODES must be adhered to.

Specifications 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements, lhese requirements are based on the Surveillance Requirements stated in the Code of federal Regulations, 10 CFR 50.36(c)(3):  ;

"Surweillance requirements are requirements relating to test, calibration,

, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Specifications 4.0.1 establishes the requirement that surveillances must be i performed during the OPERATIONAL HODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this specifi-cation is to crisure that surveillances are performed to verify the operational i

status of systems and components and tnat parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions-for Operation are applicable. Surveillance Requirennts do not have to be performed when the facility is in an OPERATIONAL H0DE for which the requirements of the associated Limiting Condition for Opera 61on do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Excep-tion are only applicable when the Special Test Exception is used as an allow-able exception to the requir:ments of a specification, i

Specification 4.0.2 er,tablishes the -< n:,$$duwhichthespecifiedtime I

interval for Surveillance Requirements may be extended. Item-er permits an allowable extension of the normal surveillance interval to facilitate surveil-

) lance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. =Its b. 14mit+-the-05e-

-ef-t he-provision s-o f-4 tem-e-to-entttre-the t-tt-41-not-tts ed-tepe atedly-t o-e x tend-

,-the turw444anc+-4nteral-beyond-that-spec-if4edr The limitogof Specifica-tion 4.0.2 h% based on engineering judgment and the recognit on that the most

- probable result of any particular surveillance being perform is the verif3pa-tion of conformance with the Surveillance Requirements. Th provisions- b at$n BEAVER VALLEY - UNIT 2 8 3/4 0-5 NOf0Sfb

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'It also provides flexibility to accommodate the length of a fuel cy','le for surveillances that are performed at each refueling outage  !

and are specified with an 18-month surveillance interval. It is not 1 intended that this provision be used repeatedly as a convenience to j extend - surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.

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. i i ATTACHMENT B Safety Analysis Beaver Valley Power Station Proposed Technical Specification Change BV-1 Change No. 169 BV-2 Chance No. 31 ,

Description of Amendment Request: The proposed amendment would revise specification 4.0.2 and associated Bases in accordance with the guidance provided in Generic Letter 89-14. This change will remove the requirement to combine the time interval for any three consecutive surveillance intervals and limiting this value to less than 3.25 times the specified surveillance interval.

Specification 4.0.2 permits surveillance intervals to be extended up to 25 percent of the specified interval. This extension facilitates l scheduling surveillance activities and allows surveillances to be postponed when plant conditions are not suitable for conducting a surveillance , for example, under transient conditions or other ongoing surveillance or maintenance activities. Specification 4.0.2 i also limits extending surveillances so that the combined time i interval for any three consecutive surveillance intervals shall not l exceed 3.25 times the specified surveillance interval. The intent of the 3,25 limit is to preclude routine use of the provision for .

extending a surveillance interval by 25 percent.  !

Commonwealth Edison Company (CECO) submitted a lead-plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.25 limit for surveillances that are performed during a refueling outage and are specified with an 18-month surveillance interval. After discussions with the staff, CECO amended the proposal to remove the 3.25 limitation for all surveillances. The amended proposal was approved by the staff on a lead-plant basis. Consistent with NRC policy, this Generic Letter provides guidance for license amendment requests to implement this line-item improvement in TS.

Experience has shown that the 18-month surveillance interval, with the provision to extend it by 25 percent, is usually sufficient to accommodate normal variations in the length of a fuel cycle. .

However, the NRC has routinely granted requests for one-time l exceptions to the 3.25 limit on extending refueling surveillances ,

because the risk to safety is low in contrast to the alternative of a l

forced shutdown to perform these surveillances. Therefore, the 3.25 limitation on extending surveillances has not been a practical limit en the use of the 25-percent allowance for extending surveillances that are performed on a refueling outage basis.

The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are performed on a routine basis during plant operation. This safety benefit is incurred when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillance . Examples of this include transient plant operating conditions or conditions in which safety systems are out of service because of ongoing surveillance or maintenance  !

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Atttchm:nt B (C:ntinund) t In such cases, the safety benefit of allowing the use of the 25-percent allowance to extend a surveillance interval would outweigh any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. Also, there is the administrative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit. On the basis of these considerations, removal of the 3.25 limit will have an overall positive impact on safety.

This change to the requirements of Specification 4.0.2 Will remove unneconsary restriction on extending surveillance requirements and will _ result in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements. Removal of the 3.25 limit will provide greater flexibility in the use of the provision for extending ' surveillance intervals, reduce the administrative burden associated with its use, and have a positive effect on safety. Therefore, these changes are administrative in nature and do not affect the UFSAR or reduce the safety of the plant.

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ATTACHMENT C

.L No Significant Hazard Evaluation Beaver Valley Power Station Proposed Technical Specification Change BV-1 Change No. 169 BV-2 Chance No. 31 Basis for proposed no significant hazards consideration J determination: The Commission has provided standards for determining whether a significant hazards consideration exits in accordance with 10 CFR 50.92(c). A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed anendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a. margin of safety.

The proposed changes do not involve a significant hazard

_._ consideration because:

1. The proposed change reflects the guidance provided in Generic Letter 89-14 for requests to revise specification 4.0.2 and associated Bases to remove the 3.25 limit applicable to extending the specified surveillance interval. Experience has shown that .the 18 month surveillance interval, with the provisions to extend it by 25 percent, is usually sufficient to accommodate normal variations in the length of a fuel cycle. However, the NRC has routinely granted requests for one time exceptions to the 3.25 limit on extending refueling surveillances because the risk to safety is low when compared to the potential risks involved in a forced plant shutdown to perform the surveillances. Therefore, the 3.25 limitation on extending surveillances has not been a practical limit on the use of the 25 ' percent allowance for extending surveillances that are performed on a refueling outage basis. Use of the 3.25 limit on extending surveillances is an administrative control not applicable to the creation of new or different kinds of accidents. Therefore, removal of this limitation is an administrative change and will not create the possibility of a new or different kind of accident from those previously evaluated.

2. The use of the allowance to extend surveillance intervals by 25 percent can result in a significant safety benefit for surveillances that are performed on a routine basis during plant operation. This safety benefit is incurred where surveillance intervals are extended at a time when conditions are not suitable for performing the surveillance. Example of this include transient plant operating conditions or conditions in which safety systems are out of service because of ongoing surveillance or maintenance activities.

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In .such. cases, the safety benefit of allowing the use of the 25 percent-allowance to extend a surveillance interval would l outweigh any- benefit derived by. limiting three consecutive 1 surveillance intervals to the 3.25 limit. Consequently, L

removal of -the 3.25 limit will have an overall positive impact on safety. Therefore, the proposed changes will not involve a significant increase in the probability or.

consequences of an accident previously= evaluated, h- 3. The proposed change to the requirements of specification L 4.0.2 will remove 'an' unnecessary restriction on extending l' surveillance ~ requirements and will result in a benefit to safety' when plant conditions are not conducive to the safe y conduct of surveillance requirements. Removal of the 3.25 l limit will provide greater' flexibility in the use of the provision for- extending surveillance intervals, reduce the administrative burden associated with its use, and have a l positive effect on. safety. .Therefore, those changes will L not involve a significant reduction in the margin of safety.

Therefore, based on the above considerations, implementation of the proposed changes will not involve a significant hazard.

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