ML20043G595
| ML20043G595 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 06/04/1990 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20043G592 | List: |
| References | |
| NUDOCS 9006200468 | |
| Download: ML20043G595 (7) | |
Text
.
s ATTACHMENT D MARKED-UP PAGES FOR IRDIOSED.CliAMES TO APPENDIX A IECHNICAL SPEClflCAIl0NS_DE IAcILITY OIERAUNG LICENSE
' *<17. NPF-66 NPF-72 AND NPfdZ i
BIRON_SIAIION BEtJ W OOD SIAIIDE Revised Pages:
3/4 0-2 3/4 0 2 B3/4 0-2 B3/4 0-2 i
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9006200468 900604
_PDR-ADOCK 05000454
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APPLICA81LITY L
SURVEILLANCE REDUIREmiNTS 4.0.1 Surveillance Reqof rements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
c 4.0.2 Each Surveillance Requirement shall be performed within the speci time interval wittp'y
\\ ( A maximum allowable extension not to exceed 25% of t h
e intervslg4d-5.
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- a. ma :. A 4.0.3 Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements -
for a Limiting Condition for Operation.
Exceptions to these ee:;.;ir6 ment.;
are stated in the individual specifications.
Surveillance Requirements do not have to be performed on inoperabl.e equipment.
4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be t
made unless the Surve111anct Requirement (s) associated with the Limiting
(
Condition for Operation have been performed within the stated surve11Tartce interval or as otherwise specified.
s 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME 1
l 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 requir 10.CFR Part 50, Section 50.55a(g), except where sper,1fic w,ed by ritten relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(1);
- b. ' Surveillance intervals specified in Section XI, 1980 Edition, I
Winter 1981 Addenda, of the ASME Soiler and Pressure Vessel Code for the inservice inspection and testing activities shall be applicable as follows in these Technical Specifications:
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8YRON - UNITS 1 & 2 3/4 0-2
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APPLICABILITY BASES The intent of this provision is to ensure that facility operation is not initiated with either required equipment or systems inoperable or other specified limits being exceeded.
Exceptions to this provision have been provided for a limited number of specifications when STARTUP with inope.able equipment would not affect plant safety.
These exceptions are stated in the ACTION statements of the t
appropriate specifications.
3.0.5 This specification delineates the applicability of each specifica-J tion to Unit 1 and Unit 2 operation.
4
- 4. 0.1 This specification provides that serveillance activities necessary to ensure the Livting Conditions for Operatio are met and will be performed during the OPER/W1ONA' MODES or other conditions for which the Limiting Condi-tions for Operation are applicable.
Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES h
or other conditions are provided in the individual Surveillance Requirements.
Serveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.
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4.0.3 The provisions of this specification set forth the criteria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation.
Under these criteria, equipment, systems, or components
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are assumed to be OPERABLE if the associated surveillance activities have been satisfactorily performed within the specified time interval.
Nothing in this provision is to be construed as definir.g equipment, systems, or components OPERABLE, when such items are found or known to be inoperable although still meeting the Surveillance Req sirements.
Items may be determined inoperable during use, during surveillance tests, or in accordance with this specification.
Therefore, ACTION statements are entered when the Surve111ence Requirements C
should have been performed rather than at the time it is discovered that the g
tests were not performed.
I 4.0.4 This specification ensures that the surveillance activities asso-ciate d with a Limiting Condition for Operation have been performed within the
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specified time interval prior to entry into an OPERATIONAL M0nE or other appli-caDie co1dition.
The intent o' this provision is to ensure tr.at surveillance
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BYRON - UNITS 1 & 2 B 3/4 0-2 l
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APPLICABILITY SURVEILLANCE REQUIREMENTS
- 4. 0.1 Surveillance Reouirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement, w~
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4.0.2 Each Surveillance Requirement shall be performed within the specified timeintervalwithy d.St K.
A maximum allowable extension not to exceed 25% of thensurveillance interval b d.
y The cMined tin-MtenvaWer any three centecutive memense-b.
-4r:ter!:h :h:14-not :=c::d 3.2E ti=: -th: :p :i'ied-weve444anee-g_s we 4.0.3 Failuri to perform a Surveillance Requirement within the specified time interval sna11 constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.
are stated in the individual specifications. Exceptions to these requirements Survaillance 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 the Limiting Condition for Operation have been performed within the stated r>urveillance interval or as otherwise specified.
4.0.5 Code Class 1, 2, and 3 components shall be applicable as follows: S Inservice inspection of ASME Code Class 1,'2, and 3 components and a.
inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Set. tion XI of the ASME Boiler and Pressure Vessel Code and applicabie Addenda as required by 10 CFR Part 50, Section 50.55a(g), except wM re specific written relief has been granted by the Commissian pursuant to 10 CFR Part 50, Section SC.55a(g)(6)(i);
b.
Serveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspec-tion and testing activities shall be applicable as follows in these Technical Specifications:
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BRAIDWOOD - UNITS 1 & 2 3/4 0-2
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APPLICABILITY BASES The intent of this provision is to ensure that facility operation is not initiated with either required equipment or systems inoperable or other specified limits being exceeded.
Exceptions to this provision have been provided for a lietted number of specifications when STARTUP with inoperable equipment wod1d not affect plant safety.
These exceptions are stated in the ACTION statements of the appropriate specifications.
3.0.5 This specification delineates the applicability of each specifica-tion to Unit 1 and Unit 2 operation.
- 4. 0.1 to ensure the Limiting Conditions for Operation are met and will during the OPERATIONAL MODES or o+her conditions for which the Limiting Condi-tions for Operation are applicable.
Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.
Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.
INSERT A i.0.2 The prevdeten: ef thic speci*ftetica previde ellert_.e telerence:
-for-per-femin;; te- :illen:: activities bejend these speci*ted i= the erine!
tu="et M anca <ete-e1.
The:: tolermee - aece::: y
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-f4enibi'ity beter:: c' stede!*ng eed - efe-- ee ceneideratieae.previd: eper:tien:1 "et '
!t" *ereciated eith e-eervei1!eere 'requency det:
The phrere net ne; te this-
. i i s i +. i.... m.he-and-pe -i * : 'A :-f:-: :: Of = r: fr:Quent-cerve111eace ectivitiet.
The tel:r:::: vele::, t:t:n :ith:r i divide:11y er cen::: tively ever n
-theec ' :t inter;;10, Or+-suff-tehntly r :trictive t: :n: r: th:+-the-r:11:bflity :::::ist:J-with-the 2 rv:111 nce : ti"ity i: net ti;nt*icently degreded bey:M-thtt-Obtained-frs th: asin 1 :p: ifi:d int:re:1.
4.0.3 he provisions of this specification set forth the criteria for Conditions for Operation. determination of compliance with the OPERABILITY requ Under these criteria, equipment, systems, or components are assumed to be OPERABLE if Use associated surveillance activities have been satisfactorily performed within the specified time interval.
Nothing in this provision is to be construed as defining equipment, systems, or components OPERABLE, when such items are found or known to be inoperable although still meeting tho fu neillance Requirements.
Items may be determined inoperable during use, during surveillance tests, or in accordance with this specification.
Therefore, ACTION statements are wntered when the Surve111once Requirements should have been performed rather than at the time it is discovered that the tests wure r.ot performed.
This specification ensures that the surveillance activities asso-4.0.4 ciated with a Limiting Condition for Operation have been performed within the specified time interval prior to entry into an OPERATIONAL MODE or other appli-cable condition.
The intent of this provision is to ensure that surveillance
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BRAIDWOOD - UNI 7S 1 & 2 B 3/4 0-2 l
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l.4 INSERT A Specificatien 4.0.2 establishes the limit for which the specified 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 survelliance; e.g., transient conditions or other ongoing survelliance or maintenance activities.
It also provides flexibility te accommodate the length of a fuel cycle for surveillances that are performed at eact 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 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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-ENCLOSURE T0-APPLICATION FOR AMENDMENT TO APPENDIX A. TECHNICAL SPECIFICATIONS OF Ehw JY_DEEEATING LICMSE_NPF-37. NPF-66. NPF-72 AND NPF-77 i
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M UNITS 0 sTATss I-NUCLEAR REGULATORY COMMISSION 3
WASHINGTON D, C. 20665 August 21, 1989 TO:
ALL LICENSEES OF OPERATING PLANTS APPLICANTS FOR OPERATING LICENSES,ANDHOLDERSOFCONSTRUCYIONPERMITS
SUBJECT:
LINE-ITEM IMPROVEMENTS IN TECHNICAL SPECIFICATIONS - REMOVAL OF THE 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GENERIC LETTER 8944)
Specification 4.0.2 of the Standard Technical Specifications allows surveil-
-lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined ti:na interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur-veillance interval.
A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur-ve111ance intervals. Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of'the 3,25 limit from Specification 4.0.2 results in a greater benefit to safety t:ian limiting the use of the 25-percent allousnee to extend surveillance intervals.- The enclosed outdance is rirovicea for tne orecaration of a license amendmefit request to Imp' ement this
'ine-item improvement in T5.
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Licensees anel applicants are encouraged to orCoose chances to plant TS that are consistent w< th the at-dance prov1< ed in the enc' osare.
Conformina amendment recos!sts wi' be expec tiously revi ewed by the NHC 3ro.1ect Manaatte for t 1e fac<
' ity.
Procosec, amen *=nts tl)a<: deviate from t iis cuidance w' 11 reau' re a lonaer. more ditai' ed rev< aw.
Please contact the )roject Manager if you have questions on tv s matter, Sincerely,
~\\b James.G. Partlow Aasociate Director for Projects
-Office of Nuclear Reactor Regulation
Enclosures:
-1.
Guidance for the Preparation of a License Amendment Request to Remove the 3.25 Limit of Extending Surveillance Intervals 2.
List of Most Recently Issued NRC Generic Letters 1
1 4t!-
-8908210105 -
l GUIDANCE FOR THE PREPARATION OF A LICENSE AMENDMENT REQUEST TO REMOVE THE 3.25' LIMIT ON EXTENDING SURVEILLANCE INTERVALS BACKGROUND Specification 4.0.2 of the Standard Technical Specifications permits surveil-lance intervals to 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 con-l ducting a surveillance, for example, under transient conditions or other ongo-l.
ing surveillance or maintenance activities.
Specification 4.0.2 also limits l
extending surveillances so that the combined time interval for any three con-l secutive surveillance intervais shall not exceed 3.25 times the specified sur-ve111ance interval. The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent.
Comanonwealth Edison Company (CECO) subaitted a lead-plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.2511mit' for surveil-lances 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.
s DISCUSSION Experience has shown that the 18-month surveillance interval, with the provi-sion to extend it by 25 percent, is usually sufficient to accosmodate normal variations in the length of a fuel cycle.
However, the NRC staff has routinely granted requests for one-time exceptions to the 3.25 limit on extending refuel-ing surveillances because the risk to safety is low in contrast to the alter-native of a forced shutdown to perform these 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.
The use of the allowance to extend surveillance intervals by 25 percent can also-result in a significant safety benefit for surveillances that are perform-ed on a routina 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 ser-vice because of ongoing surveillance or maintenance activities.
In such casos, 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 con-secutive surveillance intervals to the 3.25 limit.
Also, there is the adminis-trative burden associne.d with tracking the use of the 25-percent allowance to ensure compliance uP', n.a 1.25 limit. On the basis of these considerations, the staff concludr.),;nat emoval of the 3.25 limit will have an overall positive impact on saf'rtf.
An acceptable alternative to the existing requirements of Specification 4.0 2, 2
is the following:
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4.0.2 Each Surveillance Requirement shall be perfonned within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.
Licensees should also propose changes to update the Bases Section of Specifica-tion 4.0.2.
Generic Letter 87-09 )rovided updated Bases for Specification 4.0.2.
The following changes to tie Bases of Specification 4.0.2, as provided in Generic Letter 87-09, are shown underlined to reflect this change.
Specification 4.0.2 ' establishes the limit for which the specified time interval for Surveillance Requirements may be. extended.
It permits an allowable extension of the normal-surveillance interval tTfacilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient o conditions or other ongoing surveillance or maintenance activities.
It also provides flexibild ty to accommodate the length of a fuel cycle fW surve111ances that are performed at each refuelina outage and are spec-If1ed with a U-Lan '.8-Jmonth surveillance =1nterval.
.t is not intended that this prov' sion ce used repeatedly as a convenience to extend surve11-ance IntervaQ beyond that specified for surveillances that are not per-formed durino refueline outanes. The 11m1tati on of spec 171 cation 4.0.Z 1s based on eng' nearing judgement and the recognition.that the most probab1T result of any particular surveillance being performed is the verification of conformance with the !ceve111ance Requirements. This provision is sufficient to ensure that the reliability ensured thrEigh surve111aRe activities is not significantly degraded beyond that obtained from the specified surveillance interval.
SUMMARY
This alternative to the requirements of Specification 4.0.2 will remove an un-necessary restriction on. extending surveillance requirements and will rssult in a benefit to safety when plant conditions are not conducive to the safe' conduct of surveillance requirements. The removal of the 3.25 limit will provide greater flexibility in the use of the provision for extending surveillance in-tervals, reduce the administrative burden associated with its use, and have a positive effect on safety, l
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. Ll!T OF RECENT(1 11$('E0 GleittlC LITTIR$
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. 89 14-LINE.!TEMS TECMit! CAL $PiclFI. 06/21/89 ALL LICEN$tt$ OF CAT!0N IMPROYtMENT. REMcdAL optRATING PLANTS, 0F 3.2$ LIMIT ON EITINCING APPtitANTS FOR
$URVEILLANCE INTERVALS OPERATING LICIN$t$,
(GENERIC LITTIR 89 14)
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CONSTRUCTION PERMITS 4
49 13 GEntRIC LETTIR 49 13 7/18/89 -
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PNotLEMS AFFECTING BWR$. PWR$, AND
$AFtTY.RILAftD IQUIPNtNT VENDOR $ IN A00!T10N 70 GENERAL CODES APPtlCAOLE TO GEMAIC LETTtts 89 12 SENERIC LETTER 89 12 7/6/89 LICEN$tts TO ALL OPtRATOR LICEN11NG POWER REACTOR $
IIAMINATIONS
. BWR$ PWR$ AND VIN 00R$ IN A00!T10m TO GENERAL C00t3 APPt! CABLE 70 GENtRIC LETTER $
49 11 GEM RIC LITTtt 89 11:
6/30/09 ALL SWR PLANTS t RF30LIIT!0N OF GENERIC !$$Ut ALL LllTINGS l-.
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. ial '90! LING WAftR REACTOR APPLICABLE TO WAftt LEVEL REDUiOANCT* m al GC!IERIC LETTIR$ &
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89 10 GtMRIC LETTtR 4910:
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VEN00R$ IN Aco! TION -
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T1 GE M RAL CODES APPLICA8LE 70 GENERIC LITTIR$
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AND 10 CFR llo.54(f)
OWR $,PWR$., ADDITION YE20R$ II TO GENERAL C00t3 APPLICA4LE TO GENttlC LETTER $
UNITED STATES -
NUCLEAR REGULATORY COMMISSION EEo!N!aYEo -
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