ML20077M339

Proposed Tech Specs 4.0.3,4.0.4 & Associated Bases, Incorporating Changes Provided in Generic Ltr 87-09 Re Surveillance Intervals

ML20077M339
Person / Time
Site:	Callaway
Issue date:	08/08/1991
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20077M320	List: ML20077M318 ML20077M339
References
GL-87-09, GL-87-9, NUDOCS 9108130303
Download: ML20077M339 (12)

Text

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. to ULNRC 2457 REVISED PROPOSED TECHNICAL SPECIFICATION CHANGES Specification 4.0.3 9108130303 910808 PDH ADOCK 05000483 PDR p

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9, APPLICABILITY

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I SURVEILLANCE RTQUIREMENTS 4.0.1 Surveillance Requirements 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.

4.0.2 Eacn Surveillance Requirement shall be performed within the specified ur eillance interraLwith a_ maximum _a.llowable extension not to exceed 25%

s o the specified surveillance interval.

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. In se <6 1 q, ilure te-perf ;- :

4.0.3 Surveillan : Requirement-wit %t-the spe:ffied-l

-t4me-4aterv:1 sh:ll cons:4hte-a--f+ilure to meet the OPERASILITY reqsire-

-ments-for : Li=iting Condit4er, for Operation.

Cxceptions to these r;quir

-ments :re stated-4n-the individual specificaticns.

Serveillence Requirements do not have t0 be p rfemd en %eperable quip :nt.

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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 C rdi3100 f9J_.Qgera$ionJ14JLbeen-pstfo!med withirtttte_ state surveillance l

nterval or as othemise spec {fied.

Inse rt 7.

j 4.0.5 Surveillance Requirements for nsery ce nspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as,follows:

a.

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

CALLAWAY - UNIT 1 3/4 0-2 Amendment No. 52

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INSERT l' Adk dq 4.0.3 Faildre to perform a Surveillance Re irement within the allowed surveillan :e in rval, defined by Specifi tion 4.0.2, shall constitute noncomplia 1ce w th the OPERABILITY requi ments for a Limiting Condition for The time limits of th N~ require p t~s7e e-applicable at the

_ Operation. NIlentified A t-a urveillance Requirgment)' h s not been time it is

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performed.

The XtTIDN requirements may be delay &d for

-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 thhH wable outage ' time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance

' Requirements do not have to be performed on inoperable equipment.

f INSERT 2 '

This provision shall not prevent passage through or to_ OPERATIONAL MODES as<

required to comply with ACTION requirements.

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APPLICABILITY BASES 3.0.4 This specification provides that entry into an OPERATIONAL MODE or other specified applicability condition must be made with:

(1) the full complement of required systems, equipment, or components OPERABLE and (2) all other parameters as specified in the Limiting Conditions for Operation being met without regard for allowable deviations and out-of-service provisions contained in the ACTION state-ments.

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 inoperable equipment would not affect plant safety. These exceptions are stated in the ACTION statements of the appropriate specifications.

4.0.1 This specification pruvices that surveillance activities necessary to ensure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions 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.

dg 4.0.2 This specification establishes the limit for which the specified surveillance interval for Surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveil-lance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities.

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.

It is not intended that this provision be used repeatedly as a convenience to extend surveilla':e intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements This provision is sufficient to ensure that th ability ens d-th stLsu

. lance acti ies is_not significantly Aeg ded'beyond that btain from e speci'fied su il~e~_illance'TMeRTil.

In5er t 3 g x'

4.0.3 The p Ovi: ions-of-this-spec 4f4catten-set-for-th-the-cr4ter4a-for-

-determht4en of comp 14ance-w4th-the OPEPMt+TV-requirements-of-the Limi-tint

- Condit-ions for Operat4on. Undcr-these-criterfarequipmentr-systems cr components-

-are-as:umed to-be4REPASLE if the c societed surveillence activities have-been-

-sat 4sfactor44y-perhed 'fithin-the-spec 4f4cd time intervel,--NotMeg-4n-tMs-prov4th-4s-to-bewonst rued-a s-def4 ning-equi pmen ty-systems-or-components-OPERABEE ;

-wh en-s eeh-4tt ms-ere-found-o r-k nown-to-be-+nepe ra bl-e-e+tho ugh-st444-meet 4 eg-the-

-SurveH4anee-Requ4 rement;.

Item: mcy be-determ4ned-inoperable-during use, during-

-surveM4 anc e-t est s-or-4 n-aec ordanc e-with-this-s pecifies tio n. Therefece, ACTION-

--statements-are-entered-when-the4urve444ance-Requ4rements-should-havc been-performed

-ra ther-than-at-the-t4 me-i-t-i s-d i s cov ered-t ha t-t he-test s-we re-not-per-formed, CALLAWAY - UNIT 1 B 3/4 0-2 Amendment No. 52J

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e INSERT 3 Seecification 4.0.3 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the-provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.

Under the provisions of this specification, systems and componentjtur assumed to be OPERABLE when Surveillance Requirements have been(oted serve AnQ satis f actorily performed within tne-spec 441e444c.e + interval.

Ho D er, nothing in thi,s 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 atc the time that the allowed surveillance *was exceeded.

Completion of the @M Surveillance Requirement within the allowable outage time limits of the

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ACTION requirements restores compliance with the requirements of i

-_. Specification 4.0.3.

However, this does not negate the fact that the failure, to have performed the surveillance within the allowed surveillance interval,

~ deffneQy.JheJrWons ofJegification 4.0.2 was a violation oL,the_

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PIRABILITY requirements of a Limiting Conditiori Tor Operation.+ hat-h

-subfest-to-enf-orcement--ast i o n.

Further, the-fe44ure-to-perform-a-

-surve444ance-w4-th4n-tne-prov4s4ons-of-;peo4f4 eat 4en-4A2 is a v4olat4cn-of--a-4echn4ce4-Spec 4f4 cat 4on-r eq u i r em e nt-and-4h-therefor c,

reporteMe-event-

[

-under-the-requirements-of-10 CFR SGrMta)(2)(i)(S) bcccuse it-4s ; conditien- /

-proh4Mt ed-by-the-plant 4-Techn4ca4-Spec 4 f i c a t i o n s, f

If the allowable outage time limits of the ACTION recuirements 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, e.g.,

Specification 3.0.3, a 24-hour allowance is provided to permit a delay in implementing the ACTION recuirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed.

The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance.

The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required loj erfo~rm_tje surveillance and theyfety, significance _of the delay. ig t

com6leting thVrRsTFed 55rveTT12_nce.

s Mi s promion-a4*-pr+ddes a t.me

-14m4-t-for2-the--complet4on-of-Surve444ance Requiremenh-tha&bece'c appl 4 Gable-

-as-a-consequence-of-H00E-shanges im;osed-by ;CTIO4--requ4rerets and f or-

)

-compiet4ng-Surve441ance Recuiremen s thavare-app 44 cab 4eyhen3n-e*cg4en-tt e-requir S

f a surveI M nce is not co.Jieted wi inb-of Sperdfbit4ofdd?J is allowe6.-hour aTlowance, theWe'T mits of th requirements are applicable at that time.

When a surveillance is performed within the 24-hour allowance and the Survei llance Requirements are not met, the time limits of the ACTION requirements are applicable at the time the surveillance is terminated.

{gg4 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 OPEPABLE status.

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) to ULNRC - 2457 1

ANNOTATED PROPOSED TECHNICAL SPECIFICATION CilANGES Specification 4.0.3 and 4.0.4 l

4 tJe w P%E APPLICABILITY j

SURVEILLANCE'RTOUIREMENTS 4.0.1 Surveillance Requirements 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.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance intery 1 with q aximum allowable extension not to exceed 257.

fMEelec~ifiWsury T11ance ~ihteNa1.

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-InScr b 13 4.0.3 Failure t+-peefonn-a--Sueve444ance-Requirement-w& thin-the-specif4ed.

-t4me-inteeval-sha44-censt4 tute-a-f a44ure-to-meet - th e - OPERAS I L ITY-requice--

mcats fcr c L-imi-t4ng-Cd4en-for-Operat4cn. Scept4 ens-to-these require-

-ments cre-stated-4n-the-indtv44ual-s-pee 4f4 eat 4orn-Gurve44hnce-Requiremente dc act have-t ecfeW-on-4noperable-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 Co idi+Joofog 4eratign haye,beeoperformed-wlth n the stated surveillance j

interval or as otherwise speelfied..In se r 6 2.

4.0 5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

g 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 Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(1):

CALLAWAY - UNIT 1 3/4 0-2 Amendment No. 52

t4 EW Pac,e INSERT 1 ago a u ce4a 4.0.3 Fail re t perform a Surveillance quirement within the allowed 4

surveillan'ce in erval, defined by Speci cation 4.0.2, shall constitute noncomplia'ce w th the OPERABILITY req rements for a Limiting Condition for Operation.

time limits of the A 0N requiremynts"a applicable at the

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time it is i tTfThTth~Et a ~S'urveillance RequiregentX h s not been perfortned. TheACTIONrequirementsmaybedelayed{oru 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 all 'able outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance Requirements do not have to be performed on inoperable equipment.

INSERT 2 This provision shall not prevent passage through or to OPERATIONAL MODES as<

required to comply with ACTION requirements.

8 I

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ApPtfCABTLfTY BASES This' specification provides that entry into an OPERATIONAL MODE or 3.0.4 other specified applicability condition must be made with:

(1) the full complement of required systems, equipment, or components OPERABLE and (2) all other parameters as specified in the Limiting Conditions for Operation being met without regedd for allowable deviations and out-of-service provisions contained in the ACTION state-ments.

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.

veptions to this provision have been provided for a limited number of speci'

4. ions when startup with inoperable equipment would not affect plant safety.

These exceptions are stated in the ACTION statements of the appropriate specifications, 4.0.1 This specification pro / ides that surveillance activities necessary to ensure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveillance activities to be 3

performed without regard to the applicsble OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements. Surveillance Requirements for Special Test Exceptions need only be perfomed when the Special Test Exception is being utilized as an exception to an individual specification.

4.0.2. This specification establishes the limit for which the specified surveillance interval for Surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveil-lance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at eM refueling outage and are specified with an 18-month surveillance interval.

It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with : 5e Surveillance Requirements. This provision it, sufficient to ensure that the re.iab Gity Aegrade,d beyond ensurgd tQough-surveillance _ activities is not significantly that obtained from the specifiWsiirVeTITa~nWinTdWalm Insed 3 '

4.0.3 -Tse-preyfsions of-this spccif4eation-set 4eeth-the-et4terta-for-

-determ4 cat 4en-of-com644aee-with-the-OPERABMTFrequkement3 cf the Limiting-

-Gonditicn; fee-Operat4onr-4)nder-these-criteeier-equipmentv-systems-or-component +

.-arc c;;umed to be OPERfSLE if the-assoc 4ated-survei44ance-eet4vities-have been

-sat 4+f-aeterily per-fcred.d thin-the-speei-f-ied-t4me-interveir-% thing-tetMs-

-pecvision is to-be-construed-as-def4Mng-equipment, systc.s ee-eempenents OPEPJ3LE,

-wher such items--we-found cr-kner to be inoperabic cithough-still mcat4n9-the--

Surveillcnce Requirements, Item: mcy be-determined inoperable during u:c, dur4ng-

-su rv e i l l a n ce-tests-or-4n-ascorda nse-w4th-this-sp e c i fi c c t4 c n.

Theeefert, f4710N

-+tatement-s-we entcred whcr :he Survci44ance-Requkements :hould-haye -bccn rcrfarmed-

-rather-than et - the-t4me-41-ts-d4scovercd that the-tes t; ;cre not perfomed.

CALLAWAY - UNIT 1 B 3/4 0-2 Amendment No. 52 LA ~~ -

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NE W P%E INSERT 3 Seecificati(n 4.0.3 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.

Under the provisions of this specification, systems and components are i

assumed to be OPERABLE when Surveillance Requirement _s have been GL satisf actorily performed within the-specified-t4mefinterval.

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 althougn 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 t"ce it is identified that a surveillance has not been performed and not at.

the time that the allowed surveillancetwas excecced.

Completion of the (iMerQ Surveillance Requirement wit.hin the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3.

However, this does not negate the fact that the failure, to have performed the surveillance within tne allowed surveillance interval, deJJiped hyJh(proy,isionJ_ot Sp.ecif1catien 4.0..L_wana. viola: ion o.f_lhi" s

^CPERABILITY requirements of a Liding Condition for Operation.-that-h

-suWeet-to-enf-orcement-act4cnr-feetbec -t-he-feMure-to-perfom-a-

-surveH4ance-wi%in--the-prov4s4cns-of-Gpec4f4 eat 4on-410v2-twa-v4olat4on-of F

-Technfea4-SSec ! f i cat 4en-r-eeu4rement--and - i s, t-hereforer-a-reportable-event-

-undeM he-requirement s-o f-C FA-5GJ3fa)sH4-Hs)-dec ause-i t-44-a-cond+t4en-( ~ prob %f-ted-by-the-plant': Technica4-5pe ific o tons.

1

_______-~a If the allosable 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, e.g.,

Specification 3.0.3, a 24-hour allowance is provided to pemit a delay in implementing the AClIDH recuirements.

This provides an adequate time limit to complete Surveillance Requirements that have not been performed.

The purpose of this allowance is to permit the completion of a surveillance before a shutdown is required to comply with ACTION requirements or before other remedial measures would be required that may preclude completion of a surveillance.

The basis for this allowance includes consideration for plant condi.tions, adequate planning, availability of personnel, the time required jo pericr&the__suryanlance,_aritfherafety_ significance of the delay _in completing the required surveillance. -This prov4s4en-a4so-peev4 des-a-t4me-

-4h4-t-fee-the-compkt4en-ef-Surve+Mance-Rete 4rementi-Wet-becc e aaa Hecek

-a s-a-consequence-o f-MODE-cha nges-imposed-by-ACT44W-requ4r-ement+-and-for-

-comSet4eg-Surve444ance-RecWements-that arc appHeebh-when-en-exce:t+en-to-

-t+e-eequ4rgntmf-Spec 4ffeat4ee-~rG.f i: allowed./Tra surveiTlance is not c5pletel within the 24-hour allowance 3hentime~Timits of the Action recuirements are applicable at that time.

When a surveillance is perfomed within the 24-hour allowance and the Survei llance Requirements are not met, the time limits of the ACTION requirements are applicable at the time the surveillance is terminated, a

Surveillance Requiremer.ts do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Rcquirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

j OR t GI M A L pas E Yf8lON

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APPLICABILITY

.i BASES m 7~VN' V-x -

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.Inse rt 4 4.0.4 -This spec 4-f4eet4en-entures-that-the :urv;444encedet4vities-eteee4eted-

-with-e-04 4t4pg4endit-ien-fee-Operatien-have-beca peefemed-within-the-specified-

-time-4ateeva4-pr4er t entry-into-an-CAERATIONAb-MGOE-ec-ether-applies &ie con-

-dition,-The intes-of-tht4-provision-45-to-ensure--that-surve444anee-eetivities-

- hr,E hen-set 4fectorily d;;:nstrated-on c-current-beefe--es-feqttfred-to-meet-

-the-operabl44ty-cequiremento-of-the Limiting Condit4en Of epecatiefw

-Under-the-tems-of-this specif4 cation 7-for-example, during-tftit4el-plent-

-startup ce following-extended-plent-evtagesT-the-epp+4cebis sur eiifance-

-+ctiv444e+-must-be-pe'r-for-ed with4*-the-steted4urve444ence-intefvel-peier-to-

-p4ee4ng-ee-reteening-the-syst: Or equipment-inte4PERABtE--ttetus.

A 4.0.5 This specification ensures that 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 will be performed in accordance with a periocically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. Relief from any of the above requirements has been provided in writing by the Commission and is not a part of these Technical Specifications.

This specification includes a clarification of the frequencies for ',erforming the inservice inspection and testing activities required by Section XI af the*

c.

ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification

\\.{N is provided to ensure consistency in surveillance intervals throughort these f:

'y Technical Specifications and to remove any ambigJities relative to tne frequencies for performing the required inservice inspection and testing activi.ies.

Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda. For example, the requirements of Specification 4.0.4 to perfom surveillance activities prior to entry into an OPERATIONAL MODE or other specified applicability condition takes precedence over the ASME Boller and Pressure Vessel Code provision.which allows pumps to be tested up to 1 week after return to normal operation. And for example, the Technical Specification definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified function is declared inoperable and takes precedence over the ASME Boiler and Pressure Vassel Code provision which allows a valve to be incapable of performing its e.pecified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

CALLAWAY - UNIT 1 B 3/4 0-3 1

.*lg

-- c ORIGi VA L PA GjL -

INSERT 4:

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loecification 4.0.4 establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE 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 a MODE or condition for which these systems and components ensure safe operation of the facility.

This provision applies to changes in OPERATIONAL MODES or other specified conditions associated _with plant shutdowr. as well as startup.

Under the provision 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-l Plant startup or following a plant outage.

When a shutdown is required to comply with ACTIOM requirements, the provisions of.Spe:ification 4.0.4 do not apply because this would delay-placing the racility in a lower HODE of operation.

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