ML20239A307
| ML20239A307 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/10/1987 |
| From: | TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20239A287 | List: |
| References | |
| NUDOCS 8709170252 | |
| Download: ML20239A307 (5) | |
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APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPER-ATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an. individual Sur-veillance Requirement.
4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:
1 a.
A maximum. allowable extension not to exceed 25% of the sur-veillance interval, and b.
A total maximum combined interval time for any 3 consecutive tests not to exceed 3.25 times the specified surveillance interval.
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" :: in:p::di: :;_i; ::t INSE' RT A 4.0.4 Ent.ry into an OPERATIONAL HODE or other specified applicability condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have t'een performed within the stated surveillance interval or as otherwise specified.
4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
a.
During the time period:
1.
From issuance of the Facility Operating License to the I
start of facility commercial operation, inservice testing
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of ASME Code Class 1, 2 and 3 pumps and valves shall be i
performed in accordance with Section XI of the ASME Boiler I
and Pressure Vessel Code 1974 Edition, and Addenda through Summer 1975, except where specific written relief has been granted by the Commission.
I 2.
Following start of facility commercial operation, inservice l
inspection of ASME Code Class 1, 2 and 3 components and l
inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Beiler and Pressure Vessel Code and applicable j
Addenda as required by 10 CFR 50, Section 50.55a(g), except wbere specific written relief has been granted by the Cemmission pursuant to 10 CFR 50, Section 55.55a(g)(6)(i).
i b.
Surveillance intervals specified in Section XI of the ASME Boiler and Pressure vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:
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INSZRT "A" Failure to perform a Surveillance Requirement within the allowed surveil-lance 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 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 (equipment inoper-ability) outage timo 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 equip-ment.
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APPLICABILITY BASES
~4'.0.1 'This specification provides that surveillance activities necessary.to insure 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.
4.0.2 The provisions of this specification provide allowable toler-ances for performing surveillance activities beyond those specified in L
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 r
I the performance of more frequent surveillance activities.
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 signifi-cantly degraded beyond that obtained from the nominal stecified interval.
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4.0.4 This specification ensures that the surveillance activities associated with a Limiting Condition for Operation have been performed within the specified time interval prior to entry into an OPERATIONAL MODE or other applicable condition. The intent of this provision is to ensure that surveillance activities have been satisfactorily demonstrated on a current basis as required to meet the OPERABILITY requirements of the Limiting Condition for Operation.
DAVIS-BESSE, UNIT 1 B 3/4 0-2
INSERT "B" This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, an 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- 0PERABLE when Surveillance Requirements have been satisf9ctorily performed within the specified time interval.
However, nothing in this provision is to be construed es 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 hac not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the allowable (equipment inoperability) 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 the allowed surveillance interval, defined by the provisions of Specification 4.0.2, 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 surveillance within the provisions of Specification 4.0.2 is a violation of a Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(1)(B) because it is a condition prohibited by the plant's Technical Specifications.
If the allowable (equipment inoperability) 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 permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance ic 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 Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance Requirements that are applicable when an exception to the requirements of Specification 4.0.4 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 that the surveillance is i
terminated.
v Surveillance Requirements do not have to be performed on inoperable equip-ment because.the ACTTON requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demon--
strate that inoperable equipment has been restored to OPERABLE status, i
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