ML20247J232

Proposed Corrected Tech Specs 4.0.3 & 4.0.4 Re Surveillance Requirements & Bases

ML20247J232
Person / Time
Site:	Summer
Issue date:	05/22/1989
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20247J228	List: ML20247J224 ML20247J232
References
NUDOCS 8906010075
Download: ML20247J232 (11)

Text

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t L Enc'losure 1 to Document Ccntrol Desk Letter May 22, 1989 Page 2 of 3 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable 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 time interval with;

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

b. The combined time interval for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified surveillance interval.

G ~43-3--Failur_e_to erform a Surveillance Requirement within the spec interval shall cons i e a-fa h 'to meet

'~ the OPE uirements for a M Limiting Condition for'0peration. cto e-thesa ranuirements.are stated in the individua ions. Surveillance Requirements do w v: +n__bg_

j .parJerm on inoperable equipment.

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

Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. <_ - g g @

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. Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific weit, ten relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(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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Enclosure'l to Doch:..ent Control Desk Letter-

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INSERT 1 TO ENCLOSURE 1 4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined b/ 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 Requirements 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 />. Surveillance-Requirements do not have to be performed on inoperable equipment.

INSERT 2 TO ENCLOSURE 1 This provision:shallcnot- prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

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i ENCLOSURE 2 MAY 22, 1989 CONTENTS: Revised Bases for Specifications 4.0.3 and 4.0.4 l

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Enclosure 2 to Document Control Desk Letter May 22, 1989 Page 2 of 4 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 surveil-lance 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.

4.0.2 The provisions of this specification provide allowable tolerances for performing surveillance activities beyond 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 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 significantly degraded beyond that obtained from the nominal specified interval.

4.0.3 The provisions of this specification set forth the criteria fo 0- determ n compliance with the OPERABILITY requirements of miting Conditions for Oper

• Under this criteria, equi , stems or components are assumed to be OPERABLE 1 es ciat ei lance activities have been

% satisfactorily performed within c1 e interval. Nothing in this provision is to be pcoas defining equipment, s or components OPERABLE, cTi items are found or known to be inope able a . still e Surveillance Requirements.

0.4 This specification ensures that the surveillance activit V g associate QimitingConditionforOperationhavebee the specified time int 7e i r to entry into med within ONAL MODE or other j applicable condition. The intent o ovision is to ensure that surveil-M ance activities have b c -s s actorily demons rate a current basis as required to e PERASILITY requirements of the Limit ng Under the terms of this specification, for exa.mple, during initial plant startup or following extended plant outages, the applicable surveillance activities must be performed within the stated surveillance interval prior to placing or returning the system or equipment into OPERABLE status.

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, Enclosure 2 to Document' Control Desk Letter May 22, 1989 Page 3 of 4 INSERT 1 TO ENCLOSURE 2 Specification 4.0.3 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the previsions 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 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 4.0.3. 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 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 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 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 l 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 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 1noperable equipment has been restored to OPERABLE status.

, Enclosure 2 to Document Control Desk Letter May 22, 1989 Page 4 of 4 INSERT 2 TO ENCLOSURE 2 Specification 4.0.4 establishes the requirement that all applicable surveillance 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 shutdown as well as startup.

Under the provision of this specification, the applicable 1 /veillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operaticn are met during initial plant startup or following a plant outage.

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.

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Enclosure 3 to Document Control Desk Letter l May 22, 1989 Page 1 of 5 1

SIGNIFICANT HAZARDS CONSIDERATION The proposed amendments to Specifications 4.0.3 and 4.0.4 in Enclosure 1 are designed to resolve two generic problems. These concerns have been addressed by the Staff, and the proposed revisions to those Specifications were forwarded in Generic Letter 87-09. The following discussion identifies the j two generic concerns, the Staff's position, and a brief discussion of the i proposed revisions.

PROBLEM #1 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSING 0F SURVEILLANCE INTERVALS (Specification 4.0.3)

STATEMENT OF PROBLEM Some Action Requirements have allowable outage time limits of only one or two hours and do not establish a practical time limit for the completion of a missed Surveillance Requirement. If surveillance cannot be completed within these time limits, a plant shutdown would usually be required. Even if the Action Requirements include remedial measures that would permit continued operation, they may be stated in such a way that they 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 3.0.3 would require a shutdown.

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 shut down because completion of a missed surveillance would terminate the shutdown requirement. This is undesirable since it increases the risk to the plant and public safety for two reasons. First, the plant would be 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 testing.

This would occur when the system or component is 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 interval was exceeded. If the surveillance did demonstrate that the system or component was inoperable, it usually would be preferable to restore it to operable status before making a major change in the plant operating conditions.

Second, a shutdown would increase the pressure on the plant Staff to expeditiously complete the required surveillance so that 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.

Enclosure 3 to Document Control Desk letter May 22, 1989 Page 2 of 5

- STAFF POSITION It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The opposite is in fact the case; the vast majority of surveillance demonstrate that systems or components are in fact are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of the required surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the Technical Specifications should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance. After reviewing possible limits, the Staff has 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 /> would be 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-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.  ;

Although a missed surveillance would generally be completed in less time than this 24-hour limit allows, special circumstances may require additional time to ensure that the surveillance can be conducted in a safe manner. The time limits of Action Requirements for surveillance should start when it is identified that Surveillance Requirements have not been performed, except when the 24-hour delay is allowed in the implementation of the Action Requ;rements. Where the 24-hour time limit is allowed, the time limits of the Action Requirements are applicable either at the end of the 24-hour limit if the surveillance has not been completed or at the time the surveillance is performed if the system or component is found to be inoperable.

CHANGE TO SPECIFICATION 4.0.3 Specification 4.0.3 will be revised as follows to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an )

LC0 and to clarify the applicability of the Action Requirements and the time during which the limits apply:

" Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for I Operation. The time limits of the ACTION requirements are applicable at the 1 time it is identified that a Surveillance Requirement has not been performed. l' 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

Enclosure 3 to Document Control Desk Letter May 22, 1989 Page 3 of 5 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 />."

PROBLEM #2 -- CONFLICTS BETWEEN SPECIFICATIONS 4.0.3 AND 4.0.4 RELATED TO MODE CHANGES (Specification 4.0.4)

There are two parts of the general problem of conflicts between Specifications 4.0.3 and 4.0.4 related to mode changes. Each of these parts is discussed separately below.

Part 1 -- SURVEILLANCE REQUIREMENTS THAT BECOME APPLICABLE DUE TO ACTION REQUIREMENTS

= STATEMENT OF PROBLEM Specification 4.0.4 prohibits entry.into an operational mode or other specified condition when Surveillance Requirements have not been performed within-the specified surveillance interval. First, a conflict with this Technical Specifications exists when a mode change is required as a consequence of shutdown Action Requirements and when the Surveillance '

Requirements that become applicable have not been performed within the specified surveillance interval. For instance, the plant could previously have been in a mode for which the Surveillance Requirements were not applicable and, therefore, the surveillance may not have been performed within the specified time interval. Consequently, the Action Requirements of the LCO associated in a lower mode of operation than that required by the original shutdown Action Requirements, or other remedial actions may have to be taken, if the surveillance cannot be completed within the time limits for these actions. This is a second problem that may be encountered.

The first problem arises because conformance with Specification 4.0.4 would require the performance of these surveillance before entering a mode for which they-apply. Source and intermediate range nuclear instrumentation and cold overpressure protection systems in PWRs are examples of systems for which Surveillance Requirements may become applicable as a consequence of mode changes to comply with shutdown Action Requirements. The second problem has been mitigated by the change in Specification 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, thereby placing an appropriate time limit on the completion of Surveillance Requirements that become applicable as a consequence of mode changes to comply with Action Requirements. However, the first problem can be further resolved by a change to Specification 4.0.4.

- STAFF POSITION The potential for a plant upset and challenge to safety systems is heightened if surveillance are performed during a shutdown to comply with Action Requirements. It is not the intent of Specification 4.0.4 to prevent passage

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Enclosure 3 to Document Control Desk Letter

- May 22, 1989 Page 4 of 5-through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements.

Accordingly, Specification 4.0.4 should be modified to note that its provisions shall not prevent passage through or to operational modes as .

1 required to comply with Action Requirements. A similar provision is included in Specification 3.0.4.

- CHANGE TO SPECIFICATION 4.0.4 The following will clarify Specification 4.0.4 for mode changes as a consequence of Action Requirements:

"This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION Requirements."

Part 2 -- SURVEILLANCE REQUIREMENTS FOR EXCEPTIONS TO SPECIFICATION 4.0.4

- STATEMENT 0F PROBLEM An exception.to Specification 4.0.4 is allowed when Surveillance Requirements can be completed only after entry into a mode or specified condition for which they apply.. For example, the Technical Specifications on power distribution limits are generally exempt from Specification 4.0.4. However, upon entry into the mode or specified condition, Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within tha allowed surveillance interval. Generally, these Surveillance Requirements apply to redundant systems, and Specification 3.0.3 would' apply because they are treated as inoperable under Specification 4.0.3. Therefore, allowance of an exception to Specification 4.0.4 can create a conflict with Specification 4.0.3.

- STAFF POSITION It is not the in; cent of Specification 4.0.3 that the Action Requirements should preclude the performance of surveillance when an exception to Specification 4.0.4 is allowed. However, since Specification 4.0.3 has been changed to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, an appropriate time limit now exists for the completion of those Surveillance Requirements that become applicable when an exception to Specification 4.0.4 is allowed.

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- Enclosure 3 to Document Control Den Letter l May 22, 1989 l Page 5 of 5 The Commission has provided certain examples (48 FR 14870) of acW ons likely l to involve no significant hazards considerations. The request involved in j this case does match any of those examples. However, the proposed amendments have been reviewed and determined not to involve a significant hazards {;

ccasideration for the following reasons: ]

(1) The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the i safety analysis report is not increased.

The proposed changes to Specification 4.0.3 and 4.0.4 are designed to  ;

resolve the two generic concerns previously identified and addressed.

These changes have been determined by the Staff to result in improved Technical Specifications. These changes do not affect any of the accidents previously evaluated in the safety analysis report.

(2) The possibility for'an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created.

The proposed changes do not reflect a change in plant equipment, but resolve inconsistencies and existing undue restrictions with the Technical Specifications. The changes have been determined by the Staff to result in improved Technical Specifications which will not induce the posC hility of an accident not previously identified in the safety analysis report.

(3) The margin of safety as defined in the basis for any Technical Specification is not reduced.

The proposed changes do not affect the margin of safety as defined in the basis to any Technical Specification. These changes resolve inconsistencies and remove undue restrictions from the Technical Specifications.

Therefore, based on the above considerations, SCE&G has determined that this change does not involve a significant hazards consideration.

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