ML20098D735

Proposed TS 4.0.2 Re Consecutive Surveillance Intervals

ML20098D735
Person / Time
Site:	Sequoyah
Issue date:	05/26/1992
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20098D734	List: ML20098D733 ML20098D735
References
CON-TVA-SQN-TS-92-03, CON-TVA-SQN-TS-92-3 NUDOCS 9205290313
Download: ML20098D735 (13)

Text

s' ENCLOSURE 1 PROPOSED TECHi;1 CAL SPECIFICATION (TS) CHANGE SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 DOCKET '!OS. 50-327 AND 50-328

(*IVA-SQN-TS-92-03 )

LIST OF AFFECTED PACES Utliki 3/4 0-2 B3/4 0-3 U..iL 2 8

3/4 0-2 93/4 0-3 9205290313 920526 gDR ADOCK 05000327 PDR

APPLICABILITY SURVEILLANCE REOUIREMENTS t

(

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, r DMT O/

TS 4.0.2 Each Surveillance Requirement shall be performed within che specified -j-time interval with:

3b A maximum allowable extension not to exceed 25% of the surveillance a.

interval, but b.

The combined time interval for any 3 consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.M A

~

^

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with tr.e OPEP. ABILITY requirements for a Limiting Condition for g

Operation.

The time limits of the ACTION requirements are applicable at the RB2 time it is identified that a Surveillance Requirement has not been performed.

The ACTION 7quirements 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 pertait the completion of the surveillance when the allowahle outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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

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

Condition for Operation have been performed within the.ipecified surveillance interval or as otherwise specified.

This provision shall not prevent passage through or to OPERATIONAL MODES cs required to comply with ACTION requirements.

R82 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 cnd 3 components shall be applicable as follows:

Inservice inspection of ASME Code Class 1, 2 and 3 components ard a.

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

SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. 78 August 15, 1988

-m_.._._________..

..__..m INSERT A 4.0.2 Each Survei31ance Requirement shall be performed withfu the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

)

i i

6

?

t i

?

f 6

f l

l I

i.,. -.. - -. _ _ _.. -. - -. _. -.. -

S dPPLICABILITY

{

BASES in: tead, provided the other specified conditions are satisfied.

In this case, th s would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES S or 6, Specification 3.0_.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

J

4. 0.1 This specification provides trat surveillance activities necessary to instrn 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.

Provitions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

Surveilh*nce Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilizeo as an exception to an individual Specification.

gg Q.rH c:

f%"

V f

The provisions of this specification provide allowable tolerances for 4.0.2 i

performing surveillance activities t'eyond those specified in the nominal sur9eillance interval.

These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations.

The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance value and permits the performance of more frequent surveillance-activities.

The tolerance values, taken either individually or consecutively over 3 test intervals, are sufficiently rcstrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

A 4.0.3 This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the prcvisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPEPABILITY 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 Deen satisfactorily R8:'

performed within the specifiea 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 l

the $urveillance Requirements.

This specification a'so clarifies that the i

l 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 poin; in time it is SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 73 August 15, 1988 i

INSERT'B 4.0.2 Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended.

It pennits an allowable extension of the normal surveillance interval to f acilitate 4

surveillance scheduling and consideration of plant operating conditions that may not t e suitable for conducting the surveillance; e.g.,

transient conditions e 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 prov4.sion be used repeatedly as a convenience to extend surveillance i

intervals beyond that specified for survelliances that are not performed during refueling outages.

The limitation of 9pecification 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 the reliability ensured through survelliance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

r 9

rn,,-,.,..

-,,w-

,,,.,.,-,-,-e--

---r,

~ -,.,.

..a..,

. -.. - - - -. ~.

..~--..-,-...w

APPLICABI ITY SURVEILLANCE REQUIREMENTS

/-

(

4.0.1 Surveillance Requirement's shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an indiv w $1 Surveillance Requirement.

Y v

N

~

4.0.2 Each Surveillance Requirerr nt shall be performed within the specified time interval with:

A maximum allowable extension not to exceed 25% of the surveillance a.

NgptAtt interval, but LA.)iTM D'CRT-b.

The combined r.lme interval fcr any 3 consecutive surveillance intervals a

shall not exceed 3.25 times the specified surveillance interval.

n j

A

_e 4.0.3 Failure to perform a Surveillance Requirement within tha allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surseillance 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 R69 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 perforued on inoperable equipment.

4.0.4 Entry inte, m OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting

Q Condition for Operation have been performed within the specified surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

R69 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

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 aco rdance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Adoenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

SEQUOYAH - UNIT 2 3/4 0-2

~ Amendment No. 69 August 15, 1983

.... =.

. - - -... -.. - -. - - -.. - _.. ~... - - - - _.

INSERT A 1

4.0.2 Each Surveillanco Requirement shall be performed within the specifled surveillance interval with a maximum allowable extension not to exceed 25 percent of the specifled surveillance interval.

\\

4 4

I t

1

.,, '.., w

,.__.,_.,~.......-.,[

,,,.,,,,.,,y y

,,.,.,.,my..,,,..,...

.,_,7.,.,,,

..,7.,

t l

(

BASES 4

3.0.5 (Continued) specified conditions are satisfied.

In this case, this would mean that for one division the emergency power source must be OPERABLE ( as must be the components supplied by the emergency power source) and all re 6 ndant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfieo, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

4.0.1 This specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are m u and will be performed during the ODERATIONAL MODES or nther conditions for which the Limiting Conditions for Operation are applicable.

Provisions for additional surveil-icnce activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Require-ments. 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.

s-p b

4.0.2 The provisions of this specification provide allowable tolerances

\\

for performing surveillance activities bey,nd those specified in the nominal surveillance interval.

These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations.

The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance value and permits the performance of more frequent D W ~_.

surveillance activities.

FM The tolerance values, taken either individually or consecutively over 3 test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

j h

n A

J 4.0.3 This specification establishes the failure to perform a Surveillance t

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 l

provisions of this specification, systems and components are assumed to be I

L OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is t R69 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 tne point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded.

Complation ef the Surveillance Requirement within the SEQUI AH - UNIT 2 33/4 0-3 Amendment No. 60 August 15, 1988

~-

INSERT B 4.0.2 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 to facilitate surveillance scheculing and consideration of plant operating :onditions that may not be suitable f or conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accommodate toe length of a fuel cycle for surveillances that are performed at each refueling outage and are specifled 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 survelliances that are not performed during refueling outages.

The limitation of Specification 4.0.2 is based un engineeri;g judgement and the recognition that the most probable result of any particular survelliance 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 surveillanc' interval.

nu

f.NCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCEET NOS. 50-327 AND 50-328 (TVA-SQN-TS-92-03)

DESCRIPTION AND ?"STIFICATION FOR DELETION OF 3.2$ LIMIT ON EXTENDING SURVEILLANCE INTERVALS Y

P m

i

Deacriptlon_of_ Change t

TVA proposes to modify the Sequoyah Nuclear Plant (SQN) Units 1 and 2 Technical Specifications (TSs) to revise Surveillance Requiremr.-(

(SR) 4.0.2 and the associated bares to delete the 3.25 limit for the allowable extension of three consecutive surveillance intervals.

Reason _for_ Change The nuclear industry has experienced occasions where the 3.25 limit has required the performance of survelliances with plant conditions that are not conducive to plant safety or has required the request of one-time exceptions to the 3.25 limit from NRC.

SQN has the potential for i

requiring one of the above actions because of the surveillance interval impact of past extended outages and the possibility of extending future fuel cycles. Deletion of the 3.25 linit w.11 provide the relaxation to t

l eliminate the need to consider theso actions.

In addition to the positive effect on safety, this deletion will reduce the administrative burden associated with its use as well as incorporate the line-item l

improvement recommended by NRC in Generic Letter (GL) 89-14.

Justification far_ Change NRC issued GL 89-14 on August 21, 1989,. that supports and recommends the deletion of the 3.25 limit on extending surveillance intervals. The basis for this position is that the benefit for not performing surveillances when plant conditions are not conducive to safe conduct outweighs the importance to maintain the 3.25 limit. This propo.r1 is consistent with the guidance provided in GL 89-14 for the SR and bases changes.

The deletion of the 3.25 limit will provide greater flexibility in the use of the provisio: for extending surveillance intervals, reduce the administrative burden associated with its use, and have a positive l

effect on safety.

Entirmame.n.taLImpacLEYalua. tion

-The proposed change request does not involve an unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this change would not:

1.

Result in a significant increase in any adverse environmental impact previously evaluated 1.1 the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing r

Board, supplements to the FES, environmental impact appraisals, or decisions of the-Atomic Safety and Licensing Board.

2.

Result in a significant change in eff'uents or power levels.

3.

Result in matters not previously reviewed in the licensing basis for SQN that may have a significant environmental impact.

I o

o I.

. ~

-m

. ~.

,. _ _,,..... ~. _ _.,.,... ~. _,

__.,,.,. _,,.,. ~... _.

2 E w e-e.een 4e a

-s=44-D-----4E6WM. maA4& " eir *

-A k=44

m

-ew 6&.-

Js m__.e n A ma m J a mo A W AJ_,a

---m.amas _,m a,., maps.W _.gm ew a _3 O

t' e

PROPOSED TECllNICAL SPECIFICATION (TS) CHANGE SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (IVA-SQN-TS-92-03)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION d-f.

(-

l-l

?

w,

+

, - -, +

w v.,,,,

-,v,..,

,,,,en, a.n_,.

..,,n.,.n w

..m..--,.-,.nn,,rn-

,,_a

l Significant Hazards Evaluation 1

TVA has evaluated the proposed technical specification change and has determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of Sequoyah Nuclear Plant (SQN) in accordance with the proposed amendment will nots i

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The deletion of the 3.25 limit on extending surveillance intervels will not alter the effectiveness of surveillances that ensure the operability of equipment based on the 1.2% 1.imit that remains in effect.

Since operability will be maintained and the 3.25 limit deletion only removes a provision to prevent routine use of the 1.25 limit, the consequences of an accident is not increased.

This deletion of the 3.25 limit for extending surveillances is

. administrative only and does not have the potential for affect'.;g an accident or increasing the probability of an accident.

However, this deletion may eliminate unnecessary challenges to safety f metions created by survellia: ice performances during undesired plant conditions or because of required unit shutdown.

2.

Create the possibility of a new or different kind of accident from any previously analyzed.

As discussed above, this is an administrative change to surveillance interval extensicns only and does not have the potential for creating a new or differe..' kind of accident.

The surveillances remain the same and only the extension restrictions have been reduced but not climinated.

3.

Invol a a significant reduction in a margin of safety.

The surveillances will remain unchanged to verify adequate margins of safety and only the allowable extensions fo. surveillance performance have been revised. Therefore, no reduction in a margin of safety is involved with the deletion of the 3.25 limit on extending surveillance intervals.

+

w

• u s m

- ~

.w.

.,,~m._,.,.-.-..,.,,m-~~

_,v-

. ~.

,.c.

y 4.+,_..

-c-

,,%.r

. n

, -