ML20034E817
| ML20034E817 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/22/1993 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20034E809 | List: |
| References | |
| NUDOCS 9303010403 | |
| Download: ML20034E817 (18) | |
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ATTACHMENT I to JPN-93-003 i
PROPOSED TECHNICAL SPECIFICATION CHANGES REMOVAL OF THE 3.5 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (JPTS-89-026) l r
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9303010403 930222 PDR ADOCK 05000333 P
4 JAFNPP
- 1.0 (cont'd) opened to perform necessary operational ectivities.
R.
Safety Limits - The safety limits are limits within which the reasonable maintenance of the fuel cladding integrity 2.
At least one door in each airlock is closed and and the reactor coolant system integrity are assured.
sealed.
Violation of such a limit is cause for unit shutdown and review by the Atomic Energy Commission before 3.
All automatic containment isolation valves are resumption of unit operation. Operation beyond such a operable or de-activated in the isolated position.
limit may not in itself result in serious consequences but it indicates an operational deficiency subject to regulatory 4.
All blind flanges and manways are closed.
review.
N.
Rated Power - Rated power refers to operation at a reactor S.
Secondary Containment Intearity - Secondary containment power of 2,436 MWt. This is also termed 100 percent integrity means that the reactor building is intact and the power and is the maximum power level authorized by the following conditions are met:
operating license. Rated steam flow, rated coolant flow, rated nuclear system pressure, refer to the values of those 1.
At least one door in each access opening is closed.
parameters when the reactor is at rated power.
2.
The Standby Gas Treatment System is operable.
O.
Recctor Power Ooeration - Reactor power operation is any operation with the Mode Switch in the Startup/ Hot 3.
All automatic ventilation system isolation valves are Standby or Run position with the reactor critical and above operable or secured in the isolated position.
1 percent ratad thermal power.
T.
Deleted l
P.
R.cactor Vessel Pressure - Unless otherwise indicated, reactor vessel pressures listed in the Technical Specifications are those measured by the reactor vessel steam space sensor.
O.
Refuelino Outaae - Refueling outage is the period of time between the shutdown of the unit prior to refueling and the startup of the Plant subsequent to that refueling.
Amendment No. ' f, If4,
_ = _.
JAFNPP 1.0 (cont'd) i U.
Thermal Parameters V.
Electrically Disarmed Control Rod 1.
Minimum critical power ratio (MCPR)- Minimum value To disarm a rod drive electrically, the four amphenol type of the ratio of that power in a fuel assembly which is plug connectors are removed from the drive insert and calculated to cause some point in that fuel assembly withdrawal solenoids rendering the rod incapable of to experience boiling transition to the actual withdrawal. This procedure is equi'.afent to valving out assembly operating power fur all fuel assemblies in the drive and is preferred. Electrical disarming does not the core, eliminate position indication.
2.
Fraction of Limiting Power Density - The ratio of the W.
Hiah Pressure Water Fire Protection System linear heat generation rate (LHGR) existing at a given location to the design LHGR.
The High Pressure Water Fire Protection System consists of: a water source and pumps; and distribution system 3.
Maximum Fraction of Limiting Power Density - The piping with associated post indicator valves (isolation Maximum Fraction of Limiting Power Density valves). Such valves include the yard hydrant curb valves (MFLPD) is the highest value existing in the core of and the first valve ahead of the water flow alarm device the Fraction of Limiting Power Density (FLPD).
on each sprinkler or water spray subsystem.
4 Transition Boiling - Transition boiling means the X.
Staaaered Test Basis boiling region between nucleate and film boiling.
Transition boiling is the region in which both A Staggered Test Basis shall consist of:
nucleate and film boiling occur intermittently with neither type being completely stable.
a.
A test schedule for "n" systems, subsystems, trains or other designated components obtained by dividing the specified test interval into "n" equal subintervals.
b.
The testing of one system, subsystem, train or other designated component at the beginning of each subinterval.
Y.
Roted Recirculation Flow That drive flow which produces a core flow of 77.0 x 10
lb/hr.
Amendment No, fi, f,7f, f, If9, If4, If2, 6
JAFNPP 3.
Limitino Conditions for Ooeration 4.
Surveillance Reouirements 3.0 General 4.0 General ADolicabilitv:
Aooficabilitv:
Applies to the general LCO requirements of Section 3.
Applies to the general surveillance requirements of Section 4.
Obiective:
Obiective:
To specify the general requirements applicable to each Limiting To specify the general requirements applicable to each Condition for Operation listed in Section 3.
surveillance requirement in Section 4.
Soecification:
Soccification:
A.
Limiting Conditions for Operation and ACTION A.
Surveillance Requirements shall be applicable during the requirements shall be applicable during the OPERATIONAL OPERATIONAL CONDITIONS (modes) specified for CONDITIONS (modes) specified for each specification.
individual Limiting Condition for Operation unless otherwise stated in the individual Surveillance B.
Adherence to the requirements of the Limiting Condition Requirements.
for Operation and associated ACTION within the specified time interval shall constitute compliance with the B.
Each Surveillance Requirement shall be performed within specification. In the event the Limiting Condition for the specified surveillance interval with a maximum Operation is restored prior to expiration of the specified allowable extension not to exceed 25 percent of the time interval, completion of the ACTION statement is not specified surveillance interval.
required.
C.
In the event a Limiting Condition for Operation and/or C.
Performance of a Surveillance Requirement within the associated ACTION requirements cannot be satisfied specified time interval shall constitute compliance with because of circumstances in excess of those addressed in OPERABILITY requirements for a Limiting Condition for the specification, the unit shall be placed in COLD Operation and associated ACTION statements unless SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless otherwise required by the specification. Surveillance corrective measures are completed that permit operation requirements do not have to be performed on inoperable under the permissible ACTION or until the reactor is placed equipment.
in an OPERATIONAL CONDITION (mode) in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specifications.
Amendment No. p, 30
- ~. -
JAFNPP 4.0 BASES l
A.
This specification provides that surveillance activities Under this criteria, equipment, systems or components are necessary to insure the Limiting Conditions for Operation assumd to be OPERABLE if the associated surveillance are met and will be performed during the OPERATIONAL activities have been satisfactorily performed within the CONDITIONS (modes) for which the Limiting Conditions specified time interval. Nothing in this provision is to be for Operation are applicable. Provisions for additional construed as defining equipment, systems or components surveillance activities to be performed without regard to OPERGLE, when such items are found or known to be the applicable OPERATIONAL CONDITIONS (modes) are inoperable although still meeting the Surveillance provided in the individual Surveillance Requirements.
Requirements.
B.
Specification 4.0.B establishes the limit for which the D.
This specification ensures that surveillance activities specified time interval for Surveillance Requirements may associated with a Limiting Condition for Operation have be extended. It permits an allowable extension of the been performed within the specified time interval prior to normal surveillance interval to facilitate surveillance entry into an applicable OPERATIONAL CONDITION scheduling and consideration of plant operating conditions (mode) The intent of this provision is to ensure that that may not be suitable for conducting the surveillance surveillance activities have been satisfactorily (e.g., transient conditions or other ongoing surveillance or demonstrated on a current basis as required to meet the maintenance activities). It also provides flexibility to OPERABILITY requirements of the Limiting Condition for accommodate the length of a fuel cycle for surveillances Operation.
that are performed at each refueling outage and are specified with an 18 month surveillance interval. It is not Under the terms of this specification, for example, during intended that this provision be used repeatedly as a initial plant start-up or following extended plant outage, convenience to extend surveillance intervals beyond that the applicable surveillance activities must be performed specified for surveillarces that are not performed during within the stated surveillance interval prior to placing or refueling outages. The limitation of this specification is returning the system or equipment into OPERABLE based on engineering judgement and the recognition that status.
the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. The limit on extension of the normal surveillance interval ensures that the reliability confirmed by surveillance activities is not significantly reduced below that obtained from the specified surveillance interval.
C.
The provisions of this specification set forth the criteria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation.
Amendment No, f, 30e
i
~
t t
Attachment il to JPN-93-003 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REMOVAL OF THE 3.5 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (JPTS-89-026) 1.
DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James A. FitzPatrick Technical Specifications propose to remove the 3.5 limit on extending surveillance intervals and delete an associated definition of Surveillance Frequency as discussed below.
j Minor changes in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographical in nature and do not affect the content of the Technical Specifications.
Paoes 5 and 6. Soecification 1.0.T l
Replace the current definition:
"Sprveillance Frecuency - Periodic surveillance tests, checks, calibrations, and examinations shall be performed within the specified surveillance intervals.
These intervals may be adjusted 125 percent. The interval as pertaining to instrument and electric surveillance shall never exceed one operating cycle. In cases where the elapsed interval has exceeded 100 percent of the specified interval, the next surveillance interval shall commence at the end of the original i
specified interval."
I with the word " Deleted."
Pace 30. Specification 4.0.B Replace the current Specification:
i "Each Surveillance Requirement shall be performed within the specified time interval with:
1.
An allowable variation of f_25% of the surveillance interval, 2.
A total maximum combined interval time for any three (3) consecutive surveillance intervals not to exceed 3.5 times the specified surveillanco interval."
l with the following Specification:
i "Each Surveillance Requirement shall be performed within the specified i
surveillance interval with a maximum allowable extension not to exceed 25 l
l
. 1 to JPN-93-003 I
SAFETY EVALUATION Page 2 of 6 percent of the specified surveillance interval."
Paae 30e. Bases 4.0.B Replace the current Bases Section:
"The provisions of this specification provide allowable tolerances for performing surveillance activities beyond those specified in the normal surveillance interval.
These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations."
with the following Bases Section:
" Specification 4.0.B estab!ishes the limit for which the specified tirne 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 i
surveillance or maintenance activities). It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18 month surveillance interval.
i 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 j
performed during refueling outages. The limitation of this specification 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. The limit on extension of the normal surveillance interval ensures that the reliability confirmed by surveillance activities is not significantly reduced below that obtained from the specified surveillance interval."
Delete the phrase "C. Continued" from the top of the right column.
i 11.
PURPOSE OF THE PROPOSED CHANGES The purpose of the proposed changes to the James A. FitzPatrick Technical Specifications is to remove the Specification 4.0.8 limit of 3.5 (this is different from -
the Standard Technical Specifications lirnit of 3.25) on extending surveillance intervals as well as remove the associated definition o~ " Surveillance Frequency" in l
Specification 1.0.T. The proposed changes conform to NRC Generic Letter 89-14 (Reference 1) guidance because the changes to Specification 4.0.B and the associated Bases Section are almost identical to those proposed in the Generic Letter.
i The only differences are minor changes to the Bases Section made to correct the specification reference, a clarification of the last sentence in the Bases and the i
i l
, 1 to JPN-93-003 SAFETY EVALUATION Page 3 of 6 s
I proposed deletion from Specification 1.0.T of the associated definition made for consistency.
Specification 4.0.8 permits surveillance intervals be extended up to 25 percent of the specified interval. This extension facilitates the scheduling of 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 i
surveillance or maintenance activities. Specification 4.0.8 also limits extending 1
surveillances so that the combined time interval for any three consecutive surveillance intervals shall not exceed 3.5 times the specified surveillance interval.
{
Specification 1.0.T defines " Surveillance Frequency" as periodic surveillance tests, checks, calibrations and examinations within specified intervals and repeats the Specification 4.0.B allowance for 25 percent adjustments in surveillance intervals. It also limits surveillance intervals by requiring surveillances to be scheduled from the last scheduled surveillance rather than the adjusted date that the surveillance is performed.
I Ill.
SAFETY IMPLICATIONS OF THE PROPOSED CHANGES The proposed changes to the Technical Specifications will result in a net improvement to plant safety for surveillances performed on refueling and on a routine basis. The changes will not require modification of any plant structures, systems or components and will not alter the conclusion's of the plant's accident analyses as documented in the FSAR or the NRC staff's SER.
l The Authority has reviewed Generic Letter 89-14 and concurs with the NRC staff that elimination of the 3.5 limit on surveillance interval extension will have an overall i
positive effect on safety. The Generic Letter removed a 3.25 limit on extending consecutive surveillance intervals. The limit in the FitzPatrick Technical Specification 4.0.B is 3.5.
Experience has shown that an 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 staff has routine;r granted requests for one-time exceptions to the limit on extending refueling surveillances because the risk l
to safety is low in contrast to the alternative of a forced shutdown to perform these
{'
surveillances. Therefore, the limitation on extending surveillances has not been a practicallimit on the use of the 25 percent allowance for extending surveillances that are performed on a refueling outage basis.
l l
The use of the allowance to extend surveillance intervals by 25 percent can also l
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 i
i h
. 1 to JPN-93-003 SAFETY EVALUATION Page 4 of 6 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 activities. 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 3.5 limit.
i Specification 1.0.T is a definition of " Surveillance Frequency" that is generally repetitive of other specifications and that must be changed for consistency with the changes made to Specification 4.0.B. Standard Technical Specifications (Reference
- 2) have no definition like Specification 1.0.T and it is therefore being deleted as unnecessary. The safety significance of the deletion is evaluated by looking at the four sentences of the Specification:
1.
The first sentence states that surveillances will be performed within specified intervals. It is unnecessary since it is redundant to individual surveillance specifications.
2.
The second sentence identifies the 25 percent adjustment allowed by Specification 4.0.B. It is unnecessary since it is redundant.
3.
The third sentence limits instrument and electric surveillance intervals to one operating cycle. It is unnecessary since it is redundant to individual surveillance specifications. Additionally, it could be confusing if interpreted as a limit of 18 months (i.e., an operating cycle) on the 25 percent adjustment of Specification 4.0.B. It should not be interpreted in this manner.
4.
The last sentence limits surveillance intervals by requiring surveillances to be scheduled from the last scheduled surveillance rather than the adjusted date that the surveillance is performed. For example, if an 18 month surveillance was performed after 22 months, the next surveillance would be scheduled for 14 months later. The effect is to replace the 3.5 limit of Specification 4.0.B with the 3.25 limit (i.e., the duration of the last adjustment) of the Standard Technical Specifications. This limit is being removed for consistency with the Technical Specification change to Specification 4.0.B. Plant procedures (Reference 3) will retain this limitation under the control of plant maimgement.
On the basis of the above considerations, the removal of the 3.5 limit in i
Specification 4.0.B and the associated deletion of Specification 1.0.T will have an overall positive impact on safety.
i IV. EVAL.UATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it
.. 1 to JPN-93-003 SAFETY EVALUATION Page 5 of 6 would not:
1.
involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes will not require modification to any plant structures, systems or components. Surveillance test effectiveness and operability as determined by testing will remain the same. The proposed changes will not alter testing. The small change in reliability will not be of a nature to initiate an accident and will not effect the consequences of an accident sinc 7 mitigating systems are still available.
2.
create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes will not require modification to any plant structures, systems or components. The changes remove the limitation for extending surveillance intervals, remove the associated definition and revise Bases accordingly. The nature of the changes preclude the possibility of a new or different kind of accident.
3.
involve a significant reduction in a margin of safety, i
The proposed changes to remove the limit on surveillance interval extensions and associated definition will not cause a significant reduction in the margin of safety. Removal of the limit results in a smallincrease to allowable surveillance intervals. This would not result in a significant degradation in the reliability of systems and components under surveillance. Adherence to the limit could require forced shutdown to perform surveillance or the performance of surveillance when conditions are not suitable. It could also require routine surveillances when conditions are not suitable. The safety benefits of removing the limit are more significant than the small increase in the surveillance interval for consecutive extensions.
V.
IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment. Removal of the limit on surveillance interval extensions will have no affect on these programs or the environment.
I 1 to JPN-93 003 SAFETY EVALUATION Page 6 of 6 VI.
CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they.
1.
will not change the probability nor the consequences of an accin or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; 2.
will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report; and i
I 3.
will not reduce the margin of safety as defined in the basis for any technical specification.
I The changes involve no significant hazards consideration, as defined in 10 CFR 50.92.
)
Vll. REFERENCES 1.
NRC Generic Letter 89-14, J. G. Partlow to All Licensees of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, dated August 21,1989 regarding " Removal of the 3.25 Limit on Extending
[
Surveillance Intervals."
i 2.
NUREG-1433 " Standard Technical Specifications in General Electric Boiling Water Reactors (BWR/4)," Revision O dated September 1992.
3.
James A. FitzPatrick Nuclear Power Plant Administrative Procedure AP-4.1,
" James A. FitzPatrick Surveillance Test Program," Revision 8 dated November 4,1992.
t 4.
James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report Sections 13.8.3,17.2.11,17.2.12 and 17.2.14.
5.
James A. FitzPatrick Nuc! ear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.
ATTACHMENT lli to JPN-93-003 PROPOSED TECHNICAL SPECIFICATION CHANGES REMOVAL OF THE 3.5 LIMIT ON EXTENDING SURVEILLANCE INTERVALS MARKUP OF TECHNICAL SPECIFICATION PAGES (JPTS-89-026) i t
i i
f I
i l
I i
New York Power Authority f
i JAMES A. FITZPATRICK NUCLEAR POWER PLANT i
Docket No. 50-333 i
DPR-59 i
i
(,
V) e JAFNPP l
1.0 (cont'd) opened to perform necessary operational is the period of time between the shutdown of the Q
activities.
unit prior to refueling and the startup of l
the Plant subsequent to that refueling.
/
2.
At least one door in each airlock is closed and sealed.
R.
Sq(Cty_LIBILS - The safety limits are limits
(
within which the reasonable maintenance of the 3.
All automatic containment isolation valves fuel cladding integrity and the reactor coolant are operable or de-activated in the isolated system integrity are assured. Violation of such
- position, limit is cause for unit shutdown and review by a
the Atomic Energy Commission before resumption of 4
All blind flanges and manways are closed.
unit operation. Operation beyond such a limit may not la itself result in serious consequences H.
Bates)_ Power - Rated power refers to operation at but it lodicates an operational deticiency reactor power of,2,436 > tit.
This la also subject to regulatory review.
a termed 100 percent power and is the maximum power level authorised by the operating license. Rated S.
Secondary _Cgntainment_lutc9tity - Secondary steam flow, rated coolant flow, rated nuclear containment integrity means that the reactor system pressure, refer to the values of these building is intact and the following conditions parameters when the reactor is at rated power.
are mett O.
EtacLDLERMALQRRIAting - Reactor power operation 1.
At least one door in each access opening is is any operation with the Mede Switch in the closed.
Startup/ Hot Standby or Run position with the reactor critical and above 1 percent rated 2.
The Standby Gas Treatment System is operable.
thermal power.
l 3.
All automatic ventilation system Isolation l
P.
Egnqtotlagnol PresAura - Unless otherwise valves are operable or secured in the indicated, reactor vessel pressures listed in the isolated position.
Technical Specifications are those measured by the reactor vessel steam space sensor.
T. h tyfillanci_IttqutDCy - Periodic l
0 Enlunlina_Qutage - Refueling outage
[
(
be\\ekA f4, 14 Amendment No.
5
m
(-
r%&
3 J
JAFNPP 1.0 (cont'd)
V.
Electrically Disarmed Control Rod fsurveillanco tests, checks, calibrations, and examinations shall To disarm a rod drivo oloctrically, the four amphonol type plug bo performed within the specified survoillance intervals. Those connectors are removed from the drivo insert and withdrawal intervals may be adjusted 225 percent. The interval as s mndwing h rod iWo oNthdrawal. Ms portaining to instrument and electric survoillance shall never pr e is #vaM to Wng M N he Ms gofwmd.
sa ng hs not mate WonINon.
exceed one operating cycle. In casos where the elapsod interval has excoodod 100 percent of the specified interval, the next W.
High Pressure Water Fire Protection System surveillance interval shall commence at the end of the original LsWMntaval.
J The High Pressura Water Fire Protection System consists of: a water source and pumps; and distribution system piping with U.
Thermal Parameters associated post Indicator valves (isolation valvos). Such valves p
include the yard hydrant curb valves and the first valvo ahead ot l
1.
Minimum critical power ratio (MCPR)- Minimum value of the watpr flow alarm device on each sprinkfor or water spray the ratio of that power in a fuoi assembly which is subsystem.
calculated to cause some point in that fuel assembly t X.
Staggered Test Basis experience twiling transition to tho actual assembly l
operating power for all fuel assemblies in the coro.
A Staggered Test Basis shall consist of:
2.
Fraction of Umiting Power Donsity - The ratio of the linoar a.
A test schedule for "n" systems, subsystems, trains heat generation rate (LHGR) existing at a given location to
.l N design LHGR.
or other designated components obtained by dividing the specified test interval into "n* equal 3.
Maximum Fraction of Umiting Power Density The subintwvals.
Maximum Fraction of Umiting Power Density (MFLPD) is the highest value existing in the core of the Fraction of b.
The testing of one system, subsystem, train or other Umiting Power Density (FLPD).
designated component at the beginning of each subinterval.
4.
Transition Boiling - Transition boiling means the boiling region between nucleate and film boiling. Transition Y.
Rated Rocirculation Flow boiling is the region in which both nucleate and film boiling occur informittently with neither type being completely That drive flow which produces a core flow of 77.0 x 10 lb/hr.
6 stablo.
I Amendment No. n 64,2E,74,129, LT4 1/2 6
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- -i Each Surveillance Requirement shall be performed within the specified surveillance interval.with a j
maximum allowable extension not to exceed 25 percent of the specified surveillance interval.
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Specification 4.0.B establishes the limit for which the specified time interval for Surveillance
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3 Reouirements may be extended. It permits an allowable extension of the normal surveillance interval tc tacilitate surveillance scheduling and consideration of plant operating conditions that may not be l
1 suitable for conducting the surveillance (e.g., transient conditions or other ongoing surveillance or maintenance activities). It also provides flexibility to accommodate the length of a fuel cycle for i
l surveillances that are performed at each refueling outage and are specified with an 18 month surveillance interal. It is not 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. The limitation of this specification is based on engineering judgement and the i
j recognition that the most probable result of aay particular surveillance being p formed is the verification of conformance with the Surveillance Requirements. The limit on Aension of the i
normal surveillance interval ensures that the reliability confirmed by surveillance activities is not significantly reduced below that obtained from the specified surveillance interval.
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