ML20045G723
| ML20045G723 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/07/1993 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20045G686 | List: |
| References | |
| NUDOCS 9307150101 | |
| Download: ML20045G723 (24) | |
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i Attachment I to JPN-93-047 PROPOSED TECHNIC.AL SPECIFICATION CHANGES GENERAL SURVEILLANCE REQUIREMENT REVISIONS (JPTS-92-030) i New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 9307150101 930707 Y
PDR ADOCK 05000333 [I]
P PDR gj
- I 3.
Limitina Conditiens for Operation 4.
Surveillance Reouirements 3.0 General 4.0 General Acolicability:
Acolicability:
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 surveillance Condition for Operation listed in Section 3.
requirement in Section 4 Soccification:
Soecification:
A.
Limiting Conditions for Operation and ACTION requirements A.
Surveillance Requirements shall be applicable during the shall be applicable during the OPERATIONAL CONDITIONS OPERATIONAL CONDITIONS (modes) specified for individual (modes) specified for each specification.
Limiting Condition for Operation unless otherwise stated in the individual Surveillance Requirements.
B.
Adherence to the requirements of the Limiting Condition for B.
Each Surveillance Requirement shall be performed within the Operation and associated ACTION within the specified time specified surveillance interval with a maximum allowable interval shall constitute complicnce with the specification. In extension not to exceed 25 percent of the specified the event the Limiting Condition for Operation is restored prior surveillance interval.
to expiration of the specified time interval, completion of the ACTION statement is not 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 because specified time interval shall constitute compliance with of circumstances in excess of those addressed in the OPERABILITY requirements for a Limiting Condition for spec:fication, the unit shall be placed in COLD SHUTDOWN Operation and associated ACTION statements unless within the fo!!owing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless corrective measures are otherwise required by the specification. Failure to perform a completed that permit operation under the permissible ACTION Surveillance Requirement within the allowed surveillance or until the reactor is placed in an OPERATIONAL CONDITION interval, defined by Specification 4.0.B, shall constitute (mode) in which the specification is not applicable. Exceptions noncompliance with the OPERABILITY requirements fcr a to these requirements shall be stated in the individual Limiting Condition for Operation. The time limits of the specifications.
ACTION requirements are applicable at the time it is identified Amendment No. pI,1)d3, 30
JAFNPP 3.0 Continued 4.0 Continued D.
Entry into an OPERATIONAL CONDITION (n. ode) or other that a Surveillance Requirement has not been performed. The specified condition shall not be made when the conditions for 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 the Limiting Condition for Operation are not met and the permit the completion of the surveillance when the allowable associated ACTION requires a shutdown if they are not met outage time limits of the ACTION requirements are less than within a specified time interval. Entry into an OPERATIONAL 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 CONDITION (mode) or specified condition may be made in performed on inoperable equipment.
accordance with ACTION requirements when conformance to them permits continued operation of the facility for an D.
Entry into an OPERATIONAL CONDITION (mode) shall not be unlimited period of time. This provision shall not prevent made unless the Surveillance Requirement (s) associated with passage through OPERATIONAL CONDITIONS (modes) the Limiting Condition for Operation have been performed gdred to comply with ACTION requirements. Exceptions to within the applicable surveillance interval or as otherwise these requiiements are stated in the individual specifications.
specified. This provision shall not prevent passage through or to Operational Modes as required to comply with ACTION E.
When a system, subsystem, train, component or device is Requirements.
determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the regt.irements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s),
subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied, the unit shall be placed in COLD SHUTDOWN within the following 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 when in Cold Shutdown or Refuel Mode.
Amendment No. JVI,1)dt, 30a
JAFNPP 3.0 BASES - Continued E.
Continued E.
Continued limits of the ACTION statement associated with the Limiting As a further example, Specification 3.9.A. requires in part that Condition for Operation for the normal or emergency power two 115KV lines and reserve station transformers be available.
source, and not by the individual ACTION statements for each The ACTION statement provides a 7 day out-of-service time system, subsystem, train, component or device that is when both required offsite circuits are not OPERABLE. If the determined to be inoperable solely because of the inoperability definition of OPERABLE were applied without consideration of of its normal or emergency power source.
Specification 3.0.E., all systems, subsystems, trains, components and devices supplied by the inoperable normal For example, Specification 3.9.A. requires in part that both power sources, both of the offsite circuits, would also be emergency diesel generator systems be OPERABLE. The inoperable. This would dictate invoking the applicable ACTION ACTION statement provides for a 7 day out-of-service time statements for each of the applicable LCOs. However, the when emergency diesel generator system A or B is not provisions of Specification 3.0.E. permit the time limits for OPERABLE. If the definition of OPERABLE were applied continued operation to be consistent with tne ACTION without consideration of Specification 3.0.E., all systems, statement for the inoperable normal power sources instead, subsystems, trains, components and devices supplied by the provided the other specified conditions are satisfied. In this inoperable emergency power source, diesel generator system case, this would mean that for one division the emergency A or B, would also be inoperable. This would dictate invoking power source must be OPERABLE (as must be the components the applicable ACTION statements for each of the applicable supplied by the emergency power source) and all redundant Limiting Conditions for Operation. However, the provisions of systems, subsystems, trains, components and devices in the Specification 3.0.E. permit the time limits for continued other division must be OPERABLE, or likewise satisfy operation to be cor:sistent with the ACTION statement for the Specification 3.0.E. (i.e., be capable of performing their design inoperable emergency diesel generator system instead, functions and have an emergency power source OPERABLE).
provided the other specified conditions are satisfied. If they in other words, both emergency power sources A and B must are not satisfied, shutdown is required in accordance with this be OPERABLE and all redundant systems, subsystems, trains, specification.
components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, shutdown is required in accordance with this specification.
In Cold Shutdown and Refuel Modes, Specification 3.0.E. is not applicable, and thus the individual ACTION statement for each applicable Limiting Condition for Operation in these OPERATIONAL CONDITIONS (modes) must be adhered to.
Amendment No. pd, 30c
i 1
~
4.0 BASES A.
This specification provides that surveillance activities C.
Continued necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL interval, defined by the provisions of Specification 4.0.B, as a CONDITIONS (modes) for which the Limiting Conditions for condition that constitutes a failure to meet the OPERABILITY Operation are applicable. Provisions for additional surveillance requirements for a Limiting Condition for Operation. Under the activities to be performed without regard to the applicable provisions of this specification, systems and components are -
OPERATIONAL CONDITIONS (modes) are provided in the assumed to be OPERABLE when Surveillance Requirements individual Surveillance Requirements.
have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed B.
Specification 4.0.B establishes the limit for which the specified as implying that systems or components are OPERABLE when time interval for Surveillance Requirements may be extended.
they are found or known to be inoperable although still it permits an allowable extension of the normal surveillance meeting the Surveillance Requirements. This specification also i
interval to facilitate surveillance scheduling and consideration clarifies that the ACTION requirements are applicable when of plant operating conditions that may not be suitable for Surveillance Requirements have not been completed within the conducting the surveillance (e.g., transient conditions or other allowed surveillance interval and that the time limits of the ongoing surveillance or maintenance activities). It also ACTION requirements apply from the point in time it is provides flexibility to accommodate the length of a fuel cycle identified that a surveillanca has not been performed and not for surveillances that are performed at each refueling outage at the time that the allowed surveillance was exceeded.
and are specified with an 18 month surveillance interval. It is Completion of the Surveillance Requirement within the not intended that this provision be used repeatedly as a allowable outage time limits of the ACTION requirements convenience to extend surveillance intervals beyond that restores compliance with the requirements of Specification specified for surveillances that are not performed during 4.0.C. However, this does not negate the fact that the failure refueling outages. The limitation of this specification is based to have performed the surveillance within the allowed on engineering judgement and the recognition that the most surveillance interval, defined by the provisions of Specification probable result of any particular surveillance being performed 4.0.B, was a violation of the OPERABILITY requirements of a 4
is the verification of conformance with the Surveillance Limiting Condition for Operation that is subject to enforcement Requirements. The limit on extension of the normal action. Further, the failure to perform a surveillance within the surveillance interval ensures that the reliability confirmed by provisions of Specification 4.0.8 is a violation of a Technical l
surveillance activities is not significantly reduced below that Specification requirement and is, therefore, a reportable event obtained from the specified surveillance interval, under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant Technical Specifications.
C.
This specification establist es the failure to perform a Surveillance Requirement within the allowed surveillance d
Amendment No. J,
i 30d
JAFNPP 4.0 BASES - Continued C.
Continued C.
Continued if the allowable outage time limits of the ACTION requirements Surveillance Requirements do not have to be performed on are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or a shutdown is required to comply inoperable equipment because the ACTION requirements with ACTION requirements, a 24-hour allowance is provided to define the remedial measures that apply. However, the permit a delay in implementing the ACTION requirements.
Surveillance Requirements have to be met to demonstrate that This provides an adequate time limit to complete Surveillance inoperable equipment has been restored to OPERABLE status.
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 D.
This specification establishes the requirement that all i
requirements or before other remedial measures would be applicable surveillances must be met before entry into an required that may preclude completion of a surveillance. The OPERATIONAL CONDITION or other condition of operation basis for this a!!owance includes consideration for plant specified in the Apolicability statement. The purpose of this conditions, adequate planning, availability of personnel, the specification is to ensure that system and component time required to perform the surveillance and the safety OPERABILITY requirements or parameter limits are met before significance of the delay in comp!eting the required entry into an OPERATIONAL CONDITION or other specified surveillance. This provision also provides a time limit for the condition associated with plant shutdown as well as startup.
completion of Surveillance Requirements that become applicable as a consequence of OPERATIONAL CONDITION Under the provisions of this specification, the applicable (mode) changes imposed by ACTION requirements and for Surveillance Requirements must be performed within the completing Surveillance Requirements that are applicable when specified surveillance interval to ensure that the Limiting an exception to the requirements of Specification 4.0.C is Conditions for Operation are met during initial plant startup or allowed. If a surveillance is not completed within the 24-hour following a plant outage.
allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed When a shutdown is required to comply with ACTION within the 24-hour allowance and the Surveillance requirements, the provisions of this specification do not apply Requirements are not met, the time limits of the ACTION because this would delay placing the facility in a lower requirements are applicable at the time the surveillance is CONDITION of operation.
i terminated.
I Amendment No. JVI, }86, 30e
Attachm:nt il to JPN-93-047 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES HE.NERAL SURVElLLANCE REQUIREMENT REVISIONS (JPTS-92-030) 1.
DESCRIPTION OF THE PROPOSED CHANGES This application for an amendment to the James A. FitzPatrick Technical Specifications revises Specifications 4.0.C and 4.0.D, and their respective Bases in accordance with the guidance provided by NRC Generic Letter 87-09 (Reference 1).
The changes will update the two sections to be consistent with the Standard Technical Specifications (STS) (Reference 2) and are described below.
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.
Paaes 30 and 30a Soecification 4.0.C Starting on page 30 on into page 30s, insert between the first and second sentences the following:
" Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.B, 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 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 />."
Paae 30a. Soecification 4.0.D At the end of the specification add the following sentence:
"This provision shall not prevent passage through or to Operational Modes as required to comply with ACTION Requirements."
Pane 30c. Bases Section 3.0.1 Move the balance of Bases Section 3.0.E from page 30d and append to the end of the right column.
Paoe 30d Bases Sections 4.0.A and B Move the contents of Bases Sections 4.0.A and 4.0.B from page 30e to the left column.
Paaes 30d and 30e, Bases Section 4.0.C Move the beginning of Bases Section 4.0.C q
from page 30e to the left column of page 30d and replace the contents of this section with the following:
j "This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.8, as a condition that constitutes a failure
Attachrnent il to JPN 93-047 SAFETY EVALUATION Page 2 of 10 j
)
to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the provisions of this specification, systems and
-l 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 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 i
ACTION requirements restores compliance with the requirements of l
Specification 4.0.C. 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.B, 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 j
surveillance within the provisions of Specification 4.0.B is a violation of a Technical Specification requirement and is, therefore, a reportable event j
under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant Technical Specifications.
If 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 /> or a shutdown is required to comply with ACTION requirements, a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. ThF :,rovides an adequate time limit to complete Surveillance Requirements tr t 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 time limit for the completion of Surveillanco Requirements that become applicable as a consequence of OPERATIONAL CONDITION (mode) changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.C is allowed. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time the surveillance is terminated.
Attachment il to JPN-93-047 SAFETY EVALUATION Page 3 of 10 Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status."
Pace 30e. Bases Section 4.0.D Replace the contents of this section with the following:
"This specification establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL CONDITION or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into an OPERATIONAL CONDITION or other specified condition associated with plant shutdown as well as startup.
Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage.
When a shutdown is required to comply with ACTION requirements, the provisions of this specification do not apply because this would delay placing the facility in a lower CONDITION of operation."
11.
PURPOSE OF THE PROPOSED CHANGES The purpose of this Technical Specification (TS) change is to implement the remainder of the guidance contained in Generic Letter 87-09 not previously implemented (References 3 and 4). These changes permit a time period to perform missed surveillances and allow modo changes when Surveillance Requirements to enter a mode are not complete. Generic Letter 87-09 states in part:
"The staff concludes that these modifications will result in improved TS for all plants. Licensees and applicants are encouraged to propose changes to their TS that are consistent with these enclosures; however, these changes are voluntary for alllicensees and current OL applicants."
Lnadvertentiv Exceedina Surveillance ir tervals The first issue addressed by this submittalinvolves unnecessary shutdowns caused by Surveillance Requirement 4.0.C when surveillance intervals are inadvertently exceeded. Generally, the action requirements include a specified time interval (i.e.,
allowable outage time limit) that permits corrective action to be taken to satisfy the Limiting Conditions for Operation (LCO). When such a specified time interval is included in the action requirements, the completion of a missed surveillance within
Attachment il to JPN-93-047 SAFETY EVALUATION Page 4 of 10 this time interval satisfies Specification 4.0.C. The problem arises when action requirements have allowable outage time limits of only one or two hours and do not provide a practical time limit for the completion of a missed Surveillance Requirement. If surveillances cannot be completed the required action is often plant shutdown. Even if the action requirements include remedial measures that would -
permit continued operation, they may require actions that could prevent the performance of the required surveillance. A plant shutdown would also be required if the missed surveillance applies to more than the minimum number of systems or components required to be operable for operation under the allowable outage time limits of the action requirements, in this case, the individual specification or Specification 3.0.C would require a shutdown. The proposed change includes a time limit that allows a delay of required actions to permit the performance of the missed surveillance.
Conflict Between Specifications The other issue addressed by this submittalinvo!ves two possible conflicts between i
Specifications 4.0.C and 4.0.D. Specification 4.0.C currently states that failure to perform a surveillance on time is a failure to meet LCO operability requirements.
Specification 4.0.D currently prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within j
the specified surveillance interval.
The first conflict arises when a mode change is required as a consequence of Action Requirements and the Surveillance Requirement required by the mode has not been performed within the specified surveillance interval. Specification 4.0.D should not prevent compliance with Action Requirements.
The second conflict arises when Surveillance Requirements can only be completed after e.try into a mode or specified condition for which the Surveillance Requirements apply and the Technical Specifications allow an exception to Specification 4.0.D. Upon entry into this mode or condition, the requirements of Specification 4.0.C are not met if the Surveillance Requirements have not been performed within the allowed surveillance interval and equipment is not considered operable.
The proposed changes revise Specification 4.0.D to allow passage through or to operational modes as required to comply with Action Requirements. This resolves the first conflict. When considered with the proposed revision to Specification 4.0.C, the second conflict is resolved by the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time interval for completing the necessary surveillance.
111.
SAFETY IMPLICATIQNS OF THE PROPOSED CHANGES 10 CFR 50.36 defines Surveillance Pequirements as those requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that the facility will be within the safety limits, and that the LCO will be met. The proposed changes make two revisions to the Surveillanca
. 1 to JPN-93-047 SAFETY EVALUATION Page 5 of 10 Requirements: time is provided to perform missed surveillances; and mode changes are allowed when surveillances have been missed. These proposed changes have no affect on plant safety because they do not alter the intent of requiring surveillances nor remove the need for performing surveillances. This conclusion is based on the following:
- 1) the risks associated with the completion of a surveillance beyond the normal time limit are less than the risks inherent to transients and challenges to safety systems which occur during shutdown operations,
- 2) guidance provided in the Bases Section incorporated by this revision was developed by the NRC staff,
- 3) the determination by the NRC staff that the potential for plant upset and challenge to safety systems is increased if surveillances are performed during shutdown operations initiated by LCO Action requirements, and
- 4) the NRC staff position that it was never the intent that surveillance requirements would preclude the entry into a safer mode of operation when required by a LCO Action statement.
Inadvertentiv Exceedina Surveillance Intervals Specification 4.0.C presently states that the failure to perform a surveillance within the specified time interval shall constitute a failure to meet the LCO's operability requirements. Therefore, if a Surveillance Requirement is not met as a result of the failure to schedule the performance of the surveillance, the LCO would not be met resulting in the applicability of the LCO's action requirements.
This requirement of Specification 4.0.C is overly conservative. The NRC has determined (Reference 1) that a time interval delaying required actions to permit the performance of missed surveillances is reasonable. Generic Letter 87-09 goes on to state that this time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the i
surveillance, as well as the safety significance of the delay in completion of the surveillance. After reviewing possible limits, the NRC concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time limit for completing a missed surveillance when the allowable outage times of the action requirements are less than this time limit or when shutdown action requirements apply. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit balances the risks associated with additional time for completing a surveillance against the risks of a plant transient and challenge to safety systems when the altemative is a shutdown.
The provision of a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay in the application of the action requirements for the completion of a missed surveillance provides for plant flexibility. It provides time to obtain enforcement discretion for a Surveillance Requirement that could not otherwise be completed because of current plant conditions. If a surveillance can be
Attachment !! to JPN-93-047 SAFETY EVALUATION Page 6 of 10 performed only when the plant is shutdown, there are only two options available when a missed surveillance is discovered during power operation and continued operation is not allowed under the action requirements. The first is to shut down the plant and perform the required surveillance. The other is to seek relief from the Surveillance Requirement. Such relief would result in the processing of a Technical Specification amendment. As a matter of existing NRC policy, enforcement discretion may be granted by the NRC, if in the absence of such relief, the plant would be required to unnecessarily shutdown or would be required to delay startup.
A temporary waiver of compliance may be granted if the licensee has demonstrated in a written submittal, provided to the NRC before the Technical Specification LCO expired, that the facility can safely continue to operate without compliance with the Technical Specification during the time it will take to process the Technical Specification amendment request.
The Generic Letter provided specific guidance on the use of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit which has been included in the bases.
A missed surveillance can generally be completed in less time than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> but special circumstances may require additional time to ensure that the surveillance can be conducted ir' safe manner. This is provided by existing time limits in action requirements. The time limits of action requirements are applicable either at the end of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit if the surveillance is not completed or at the time the surveillance is terminated if the system or component is found to be inoperable.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit does not waive compliance with Specification 4.0.C. Under Specification 4.0.C, the failure to perform a Surveillance Requirement will continue to constitute noncompliance with the Operability Requirements of a LCO and bring into play the applicable action requirements.
Specification 3.0.B states that the Technical Specifications are being complied with when action requirements are met within specified time intervals. Although Specification 4.0.B allows for an extension of the surveillance interval and for the completion of the surveillance within this time interval without violation of this Specification, missing the Surveillance Requirement is a violation of the Operability Requirements of a LCO as defined by Specification 4.0.C. To avoid misinterpretation, Generic Letter 87-09 specifically states that: (1) Specification i
3.0.B shall not be construed to imply that the completion of a missed surveillance within the allowable outage f(ne limits of the action requirements, whether or not the additional 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time, hmit is included, negates the violation of Specification 4.0.C, and (2) that the failure to perform a surveillence within the allowable i
surveillance interval defined by Specification 4.0.B constitutes a reportable event under 10 CFR 50.73(a)(2)(1)(B) because it is a condition prohibited by the plant Technical Specification.
Conflict Between So_qcifications Current Specification 4.0.D requirements state that " entry into an operation condition (mode) shall not be made unless the surveillance requirement (s) associated with the
Attachrnsnt 11 to JPN 93-047 SAFETY EVALUATION Page 7 of 10 LCO have been performed within the applicable surveillance interval..." This specification could require placing an Action Requirement mode change on hold while the necessary surveillances are performed. The NRC staff has concluded that the potential for a plant upset and challenge to safety systems is heightened if such surveillances are performed during implementation of a LCO Action statement which requires a plant shutdown.
The NRC states in Generic Letter 87-09 that it did not intend for Specification 4.0.D to prevent passage through or to operational modes when complying with Action Requirements. Such Action required mode changes are performed to increase safety and system stability. To prevent entry into a safer mode of operation because of an administrative requirement for verifying operability of systems for that mode is incongruent with the safety intent of the LCO Action requirement. Accordingly, the proposed changes modify Specification 4.0.D to note that its provisions shall not i
prevent passage through or to operational modes as required to comply with Action Requirements. Specification 4.0.C allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the surveillance once the safer mode is entered. The missed surveillance is still reportable and may be discussed as part of the reportable event that required the mode change. A similar provision in Specification 3.0.D has been previously implemented (References 3 and 4).
IV.
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION I
i i
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 would not:
- 1. involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change to Specification 4.0.C will allow a delay of implementation of Action Requirements for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under certain conditions when a surveillance has been missed. Additionally, in some cases a surveillance should be delayed until proper plant conditions exist. This will not significantly increase the probability or consequences of an accident,in that surveillances normally verify system or component operability as opposed to discovering inoperability.
Without the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay,it is possible that a missed surveillance would force the plant to shutdown. Avoidance of these unnecessary shutdowns is beneficial since this reduces reactor vessel stresses which far outweighs any disadvantages associated with the additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in which to perform a missed surveillance.
If a plant shutdown is required before a missed surveillance is completed, it is likely that it would be conducted when the plant is being shutdown because the completion of a missed surveillance would terminate the shutdown requirement.
This is undesirable since it increases the risk to the plant and public safety by:
placing the plant in a transient state involving changing plant conditions that offer the potential for an upset that could lead to a demand for the system or component being tested. This would occur when the system or component is
. 1 to JPN-93-047 SAFETY EVALUATION Page 8 of 10 either out of service to allow performance of the surveillance test or there is a lower level of confidence in its operability because the normal surveillance was exceeded. If the surveillance does demonstrate that the system or component is inoperable, it would be preferable to restore it to an operable status before making a major change in plant operating conditions.
a shutdown would increase the pressure on the plant staff to expeditiously complete the required surveillance so the plant could be returned to power operation. This would further increase the potential for a plant upset when both the shutdown and surveillance activities place a demand on the plant operators.
The proposed change to Specification 4.0.D will allow passage through an operational mode if required to comply with an Action Statement. This includes entry into a mode even if required surveillances for that mode are incomplete.
The proposed Technical Specification will not result in a change to the design or operation of the facility, therefore, this change will not result in an 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.
The proposed change to Specification 4.0.C will allow the plant to continue operation for an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after discovery of a missed surveillance.
Missing a surveillance does not mean that a component or system is inoperable.
In most cases, surveillance demonstrates the continued operability of the components and systems. This change will not affect the design of the plant and will not allow the plant to be operated outside the currently allowed modes of operation.
The proposed change to Specification 4.0.D will alleviate a conflict within the Technical Specifications. The change is necessary to allow the plant to proceed through or to required operational modes to comply with Action statement requirements even if applicable Surveillance Requirements may not have been performed. This change can not initiate a new or different kind of accident.
- 3. involve a significant reduction in the margin of safety.
The proposed change to Technical Specification 4.0.C will allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a missed surveillance. In some cases this will eliminate the need for a plant shutdown. The overall effect is a net gain in plant safety by avoiding unnecessary shutdowns and the associated system transients due to missed surveillances.
The proposed change to Technical Specification 4.0.D will eliminate an internal conflict within the Technical Specifications and allow the plant to proceed through or to required operational modes to comply with Action Requirements even if
l l
, 1 to JPN 93-047 SAFETY EVALUATION Page 9 of 10 applicable Surveillance Requirements for that mode may not have performed.
This change does not affect any margin of safety.
Implementation of these changes to the FitzPatrick Surveillance Requirements is consistent with the guidance provide by the NRC in Generic Letter 87-09. The NRC staff encourages licensees to implement these technical specification changes since they have concluded that this will result in improved Technical Specifications for all plants.
V.
IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Program at the FitzPatrick plant, nor will the changes impact the environment. These changes will not result in any new releases to the environment since there are no hardware, structural, or operational changes. For these same reasons, the changes pose no radiological or fire hazards. The changes do not alter the goals or intent of the relevant SRs.
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 accident 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
- 3. will not reduce the margin of safety as defined in the basis for any technical specification.
The changes involve no significant hazards consideration, as defined in 10 CFR 50.92.
Vll. REFERENCES 1.
NRC Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," dated June 4,1987.
2.
NRC NUREG-1433 " Standard Technical Specifications in General Electric Boiling Water Reactors (BWR/4)," Revision 0, dated September 1992.
Attachment il to JPN-93-047 SAFETY EVALUATION Page 10 of 10 3.
NYPA letter, R. E. Beedle to NRC, dated November 20,1992 (JPN-92-066)
" Proposed Changes to the Technical Specifications General Limited Condition for Operation Revision (JPTS-88-021)."
4.
NRC letter, B. C. McCabe to R. E. Beedle, dated December 17,1992 ([[::JAF-92-329|JAF-92-329]]) transmits Amendment 184.
5.
James A. FitzPatrick Nuclear Power Plant Safety Evaluation. Report (SER), dated November 20,1972, and Supplements.
Attachment ill to JPN-93-047 PROPOSED TECHNICAL SPECIFICATION CHANGES GENERAL SURVEILLANCE REQUIREMENT REVISIONS IVIARKUP OF TECHNICAL SPECIFICATION PAGES (JPTS-92-030)
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
JAFNPP 3.
Limitino Conditions for Ooeration 4.
Surveillance Recuirements 3.0 General 4.0 General Aoolicabilitv:
Aenticabihtv:
Applies to the general LCO requirements of Section 3.
Applies to the general surveillance requirernents 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:
Soecification:
A.
Limiting Conditions for Operation and ACTION A.
Surveillance Requirements shall be appiscable 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 entess 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.
requered.
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 constituto 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 performe 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 Inserd requirements shall be stated in the individual specifications.
+A" If. l Amendment No.
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JAFNPP O verOow 0f 3.0 Continued 4.0 Continued I,,g M
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D.
Entry into an OPERATIONAL CONDITION (mode) or other D.
Entry into an OPERATIONAL CONDITION (mode) sha!! not be specified cond tion shall not be made when the conditions for made unless the Surveillance Requirement (s) associated with l
the Limiting Condition for Operation are not rnet and the the Limiting Condition for Operation have been performed associated ACTION requires a shutdown if they are not met within the applicable surveillance interva! or as otherwise within a specified time interval. Entry into an OPERATIONAL specified.
CONDITION (mode) or specified condition may be made in
^
accordance with ACTION requirements when conformance to them permits continued operation of the facility for an j
unlimited period of time. This provision shall not prevent Insed
,,8 w
passage through OPERATIONAL CONDITIONS (modes) required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual specifications.
E.
When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s),
subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requwements of this specification. Unless both conditions (1) and (2) are satisfied, the unit shall be placed in COLD SHUTDOWN within the following 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 when in Cold Shutdown or Refuel Mode.
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munt also lie OPERADI,E.
If tlicsc conditionn are not natisfleil, slivatdown is re<psircel in I
accordance wi th this specificat ion.
In Cold Sfiutdown and Trefuel Ptodes, Spect-fication 3.O'.E.
is not applicable, and 1
tinas the individual ACTIOtl statement for each applicable Limitinef Con <lltion for Operatinn In these OPElmTIONAI. CONDITIONS (m<xle r:) must be adhera*1 to.
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- A 4.0 BASES - Coa b od f Ye 3OJ e
r this p(sieria. eatpginent, sys) ems or com nts are.
U TA.
Ttus specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation sumep,o be OPEpABLE if t ssociated s eillance are met and will be performed during the OPERATIONAL activipds have satisfact sly perior within 1 s
ied ti erval. No ng in this ovision ' o be CONOfTIONS (modeel for which the Limiting Conditions strued a fining e pment, sy ms or for Operation are apqdeside. Provisions for additional surveellence activities to be performed without regard to PERAB, when items are or wn to the applicable OPERATIONAL CONDITIONS (modes) are inoper alt till meet' the Sur e
He ements.
provided in the indevedual Surveellance Requirements.
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B.
Specification 4.0.B establishes the lirit for which the This specification ensures that surveillance activities associated with a Limiting Condition for Operation have specified time interval for Surveillanco Requirements may been performed within the specified time interval prior to be extended. It permits an allowable sutensson of the normal surveillance interval to facilitate v.wilence entry into en applicable OPERATIONAL CONDITION scheduhng and consadoration of plant opera: ting conditions (mode). The intent of this provision is to ensure that 7
that may not be suitable for conducting the surveillance surveillance activities have been satisf actordy demonstrated on a current basis as required to rneet the '
(e.g., tranneent conditions or other ongoeng surveillance or maintenance activities). It also provides flexibility to OPERABILITY requirements of the Limiting Condition for i
accommodate the length of a fuel cycle for surveillances Operation.
that are performed at each refueleng outage and are Under the terms of this specification, for example, during specified with an 18 month surveellence interval. It is not intended that this prowesson be used repeatedly as a initial plant start-up or following extended plant outage, convensonce to eatend surveellence interva:s beyond that the applicable surs 'rce activities must be performed i
within the stated surveellence interval prior to placing or specified for survedences that are not performed during refuehng outages.. The lunetation of this specification is returning the system or equipment into OPERABLE bened on enginnenne F t-c4 and the recognition that status.
the most probable result of any porticulw surveillance j beang perfommed is the veriscation of conformance with R e p fctc e 'evs bf l
l the Survomance Reedroments. The linit on extension of e
o the normal surveWence intervel ensures that the releelulity yod' hSF conNrmed by surveWence activities is not significantly reduced beloor that obtained from the specified i
}< survesence interwel.
7 4
r TC.
The previo6one of this specification set forth the criteria for determination of cC we with the OPERABILITY requirements of the Limiting Conditions for Operation.
m y u, u;n Lw4."c l
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INSERT "A" Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.B, 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 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 />.
INSERT "B" This provision shall not prevent passage through or to Operational Modes as required to comply with ACTION Requirements.
INSERT "C" This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.B, 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 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.C. 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.B, was a violation of the OPERABILITY requirements of a Limiting Condit on for Operation.that is subject to i
enforcement action. Further, the failure to perform a surveillance within the provisions of Specification 4.J.B is a violation of a Technical Specification
,,,e requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant 3
Technical Specifications.
j If 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 /> or a shutdown is required to comply with ACTION requirements, a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance j
Requirements that have not been performed. The purpose of this allowance j
is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial rneasures 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 j
surveillance and the safety significance of the delay in completing the required surveillance. This provision also provides'a time limit for the completion of Surveillance Requirements that become applicable as a consequence of OPERATIONAL CONDITION (mode) changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.C is allowed. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time.
When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time the surveillance is terminated.
Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.
INSERT "D" This specification establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL CONDITION or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into an OPERATIONAL CONDITION or other specified condition associated with plant shutdown as well as startup.
Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage.
o M' '
When a shutdown is required to comply with ACTION requirements, the provisions of this specification do not apply because this would delay placing the facility in a lower CONDITION of operation.