ML20308A398
| ML20308A398 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/06/2014 |
| From: | Technical Specifications Task Force |
| To: | Office of Nuclear Reactor Regulation |
| Honcharik M | |
| References | |
| TSTF-RPP-14-01 | |
| Download: ML20308A398 (6) | |
Text
TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY October 6, 2014 REGULATORY POSITION PAPER TSTF-RPP-14-01 Title SR 3.0.3 Cannot Be Applied to SRs that Will Not Be Performed Prior to Expiration of the Specified Frequency Problem Statement There is sometimes confusion as to whether a licensee may apply the allowance in Surveillance Requirements (SR) 3.0.3 when it is realized that an SR will not be performed within its specified Frequency prior to the expiration of the specified Frequency.
Background
SR 3.0.3 is based on NRC Generic Letter (GL) 87-09 (Reference 1). GL 87-09 was published to address three specific issues with the application of Technical Specifications. One of those issues was missed Surveillances. The Generic Letter states:
The second problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceeded. The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO. It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are OPERABLE. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for performing a missed surveillance before Shutdown Requirements apply, the TS should include a time limit that allows a delay of required actions to permit the performance of the missed surveillance based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and, of course, the safety significance of the delay in completing the surveillance. The staff has concluded that 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 limit, or when time is needed to obtain a temporary waiver of the Surveillance Requirement.
To avoid any conflict among or misreading of Specifications 3.0.2, 4.0.3, and 4.0.2, the staff wishes to make clear (1) that Specification 3.0.2 shall not be construed to imply that the completion of a missed surveillance within the allowable outage time limits of the Action Requirements -- whether or not the additional 24-hour time limit is included Page 1
TSTF-RPP-14-01 Page 2 negates the violation of specification 4.0.3, and (2) that the failure to perform a surveillance within the allowable surveillance interval defined by Specification 4.0.2 constitutes a reportable event under 10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant's TS.
Specification 4.0.3 will be revised as follows to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO 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 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 />.
(emphasis added.)
The Improved Standard Technical Specifications (ISTS) implements the staffs recommendations in GL 87-09 as SR 3.0.3. In 2001, the NRC approved TSTF Traveler TSTF 358, Revision 6, "Missed Surveillance Requirements." TSTF-358 revised SR 3.0.2 to provide a risk-informed extension to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance in SR 3.0.2 to up to the limit of the specified Frequency. However, TSTF-358 and the NRC Safety Evaluation (References 2 and 3) did not change the applicability of SR 3.0.3 and are based on addressing "missed Surveillances."
The industry implementation guide for TSTF-358, TSTF-IG-06-01 (Reference 4) states:
4.1 Identification of a Missed Surveillance and Use of SR 3.0.3 A missed surveillance can occur in a number of ways. Surveillances may be overlooked as a result of an error in surveillance tracking or a failure to follow procedure. On the other hand, a procedural inadequacy may be discovered that calls into question the results of the last performance of the surveillance. While the surveillance may have been performed within the specified frequency, the procedural inadequacy caused the surveillance to be inadequate or incomplete. For example, past reviews of complex systems, such as the reactor protection system or the engineered safety features actuation system, have identified portions of circuits that have not been fully tested. Similarly, response time test procedure reviews have identified components that have not been properly response time tested. These situations would result in the associated surveillance tests to be considered "missed."
On discovery of a missed SR, either the associated LCO is declared "not met" and the Actions followed or SR 3.0.3 is invoked. If SR 3.0.3 is used, the licensee must have Page 2
TSTF-RPP-14-01 Page 3 confidence that the SR, when performed, will be successful (i.e., that the associated system is OPERABLE or associated parameters are within limit).
The Frequently Asked Questions Section of the implementation guide states:
Q2: Can SR 3.0.3 be used to delay performance of a Surveillance whose Frequency has not yet expired. For example, if it is determined that a Surveillance will not be able to be performed within its Frequency due to failure of test equipment or sample lines or due to current operating conditions?
A2: SR 3.0.3 may not be used to delay performance of Surveillance whose Frequencies have not yet expired. SR 3.0.3 is based on changes proposed in Generic Letter 87-09. The Generic Letter stated, "The second problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceeded." (Emphasis added). SR 3.0.3 specifically discusses the missed SR in past tense - "If it is discovered that a Surveillance was not performed within its specified Frequency..." Furthermore, the Bases of SR 3.0.3 state, "Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals."
In 2008, the Technical Specifications Task Force submitted TSTF-512, "Revise SR 3.0.3 to Address SRs that Cannot be Performed or Are Not Met" (Reference 5). Part of this change was a revision to SR 3.0.3 to allow the missed Surveillance provision to be applied when it is discovered that the Surveillance cannot be performed before the expiration of the specified Frequency. On May 1, 2009, the NRC notified the TSTF that the Traveler would not be accepted for review (Reference 6). Regarding the change to SR 3.0.3, the NRC stated:
The proposed SR 3.0.3(b) exception to SR 3.0.1 would apply when a licensee discovers it will not be possible to perform a surveillance within its specified frequency due to conditions that prohibit the performance of the surveillance but do not render the surveillance not met. Regarding this change, general surveillance requirement SR 3.0.2 already contains an allowance to consider an SR met if the Surveillance is performed within 1.25 times the interval specified in the surveillance Frequency.
Current Requirements ISTS Surveillance Requirement 3.0.3 states:
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
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TSTF-RPP-14-01 Page 4 If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(emphasis added.)
The ISTS SR 3.0.3 Bases state, in part:
SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been performed within the specified Frequency. A delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed within its specified Frequency in accordance with SR 3.0.2.
This delay period provides an adequate time to perform the Surveillance. This delay period permits the performance of a Surveillance before complying with Required Actions or other remedial measures that might preclude performance of the Surveillance.
When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed within the specified Frequency, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the Surveillance should be performed at the first reasonable opportunity.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency is provided to perform the Surveillance, it is expected that the Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.
(emphasis added.)
Note that the term "specified Frequency" is defined in SR 3.0.2 as "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified Page 4
TSTF-RPP-14-01 Page 5 condition of the Frequency is met." In other words, the "specified Frequency" is the Frequency given in the SR plus the 25% extension allowed by SR 3.0.2.
Evaluation SR 3.0.3, the SR 3.0.3 Bases, and Generic Letter 87-09 make it clear that SR 3.0.3 can only be used if it is discovered that a SR was not performed after the specified Frequency has expired.
- The use of past tense in SR 3.0.3, the Bases, and the Generic Letter make clear the specified Frequency has previously expired. SR 3.0.3 states "If it is discovered that a Surveillance was not performed within its specified Frequency".
- Explicit statements in the Bases, such as, "when a Surveillance has not been performed within the specified Frequency," and "A delay period ... applies from the point in time that it is discovered that the Surveillance has not been performed."
- References in the Generic Letter and the Bases to "missed" Surveillances. A Surveillance cannot be "missed" before expiration of the specified Frequency.
In addition, applying SR 3.0.3 to SRs that cannot be performed within the specified Frequency is not supportable. It would have the effect of extending the SR 3.0.2 allowance to 2.5 times the Frequency. A licensee would simply need to delay an SR until there is insufficient time to perform it within the specified Frequency, invoke SR 3.0.3, and gain an additional specified Frequency to perform the SR (i.e., 2.5 times the Frequency since the last performance). This was clearly not the intent of the provision.
Regulatory Position If it is discovered that an SR has not been performed after the specified Frequency of the SR has expired, SR 3.0.3 allows up to the SR specified Frequency to perform the Surveillance (assuming a risk assessment supports the extension). If, however, it is discovered an SR cannot be performed before the specified Frequency has expired, SR 3.0.3 does not apply and the Surveillance must be declared not met when the specified Frequency has expired.
References
- 1. Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operations and Surveillance Requirements,"
dated June 4, 1987.
- 2. Letter from the Nuclear Energy Institute to Dr. William D. Beckner, NRC, transmitting TSTF-358, Revision 6, and TSTF-419, Revision 0, dated September 19, 2001 (ADAMS Accession Number ML012690166).
- 3. Federal Register Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Missed Surveillances Using the Page 5
TSTF-RPP-14-01 Page 6 Consolidate Line Item Improvement Process, dated September 24, 2001 (ADAMS Accession Number ML012670082.)
- 4. TSTF-IG-06-01, "Implementation Guidance for TSTF-358, Revision 6, "Missed Surveillance Requirements," dated May 2006.
- 5. Letter from the Technical Specifications Task Force to NRC Document Control Desk, "
Transmittal of TSTF-512, Revision 0, "Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met," dated October 14, 2008 (ADAMS Accession Number ML082880503).
- 6. Letter from Bruce A. Boger (NRC) to Technical Specifications Task Force, "Request for the Review of TSTF-512, Revision 0, 'Revise SR Surveillance Requirement 3.0.3 To Address SRs that Cannot be Performed or are not Met'," dated May 1, 2009, (ADAMS Accession Number ML090230254).
Industry Review This regulatory position paper was reviewed by the BWROG Licensing Committee and the PWROG Licensing Committee between July 25, 2014 and August 13, 2014. Comments were resolved to the satisfaction of the reviewers.
This regulatory position paper represents the consensus opinion of the Technical Specification Task Force, the BWROG Licensing Committee members, and the PWROG Licensing Committee members. It is not binding on any Owners Group member company.
This regulatory position paper is endorsed by the TSTF members.
Robert A. Slough (PWROG/W) Joseph A. Clark (BWROG)
Otto W. Gustafson (PWROG/CE) Henry L. Hegrat (PWROG/B&W)
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