RS-24-077, Application to Revise Technical Specifications for Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process
| ML24344A270 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Byron, Braidwood, Ginna  |
| Issue date: | 12/09/2024 |
| From: | Steinman R Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-24-077 | |
| Download: ML24344A270 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-24-077 December 9, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Facility Operating Licenses Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 R.E. Ginna Nuclear Power Plant, Unit 1 Facility Operating License DPR-18 NRC Docket No. 50-244
Subject:
Application to Revise Technical Specifications for Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process
References:
1.
TSTF-475, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action," dated May 22, 2007 (ADAMS Accession No. ML071420428) 2.
NRC Notice of Availability of Model Application Concerning Technical Specification Improvement To Revise Control Rod Notch Surveillance Frequency, Clarify SRM Insert Control Rod Action, and Clarify Frequency Example, dated November 5th, 2007 (ADAMS Accession No. ML073050017) 3 NRC Notice of Availability of Revised Model Proposed No Significant Hazards Considerations Determination for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-475, Revision 1, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action," dated May 17, 2010 (ADAMS Accession No. ML101030613)
December 9, 2024 U.S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for the Braidwood Station (BRW), Units 1 and 2; Nos. NPF-37 and NPF-66 for Byron Station (BYR), Units 1 and 2; Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant (CAL), Units 1 and 2; No.
DPR-18 for R.E. Ginna Nuclear Power Plant (GIN), Unit 1. Specifically, CEG requests adoption of TSTF-475, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action" (Reference 1), an approved change to the Standard Technical Specifications (STS), into each listed site's Technical Specifications (TS).
The proposed change would revise the Example 1.4-3 in Section 1.4 Frequency to clarify the applicability of the 25% allowance of SR 3.0.2 to time periods discussed in NOTES in the SURVEILLANCE column as well as to time periods in the FREQUENCY column by adding a phrase referencing the allowed 25% extension in two additional places in the discussion for Example 1.4-3. provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked-up to show the proposed TS change. Attachment 3 provides the corresponding marked-up TS Bases pages and is provided for information only.
The proposed change has been reviewed by each listed site's Plant Operations Review Committee, respectively, in accordance with the requirements of the CEG Quality Assurance Program.
CEG requests approval of the proposed license amendment by December 9, 2025. Once approved, the amendment shall be implemented within 60 days.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.
There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Mr. Jared A. Smith at (779) 231-6155.
I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 9th day of December 2024.
Respectfully, Rebecca L. Steinman Sr. Manager Licensing Constellation Energy Generation, LLC
- Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2024.12.09 15:10:57
-06'00'
December 9, 2024 U.S. Nuclear Regulatory Commission Page 3 Attachments:
- 1. Evaluation of Proposed Changes
- 2. Mark-up of Technical Specifications Pages
- 3. Mark-up of Technical Specifications Bases Pages - For Information Only cc:
NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Project Manager, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Project Manager, Byron Station NRC Senior Resident Inspector, Calvert Cliffs Nuclear Power Plant NRC Project Manager, Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector, R. E. Ginna Nuclear Power Plant NRC Project Manager, R. E. Ginna Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety A. L. Peterson, NYSERDA B. Frymire, NYSPSC S. Seaman, Maryland
ATTACHMENT 1 Evaluation of Proposed Changes
Subject:
Application to Revise Technical Specifications for Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements / Criteria
4.2 Precedents
4.3 No Significant Hazards Consideration 4.4 Conclusion
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
ATTACHMENT 1 Evaluation of Proposed Changes Page 2 1.0
SUMMARY
DESCRIPTION CEG requests adoption of TSTF-475, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action" (Reference 6.1), an approved change to the Standard Technical Specifications (STS), into each listed site's Technical Specification (TS). The proposed change revises the Example in Section 1.4 Frequency to make it clear that the 1.25 interval in SR 3.0.2 is applicable to time periods discussed in NOTES in the SURVEILLANCE column in addition to the time periods in the FREQUENCY column.
2.0 DETAILED DESCRIPTION Example 1.4-3 in Section 1.4 Frequency is revised to clarify the applicability of the 25%
allowance of SR 3.0.2 to time periods discussed in NOTES in the SURVEILLANCE column as well as to time periods in the FREQUENCY column. This is accomplished by revising two sentences:
Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (plus the extension allowed by SR 3.0.2) ZLWKSRZHU573
If the surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval (plus the extension allowed by SR 3.0.2), there would then be a failure to perform a surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
The changes are consistent with the Nuclear Regulatory Commission (NRC)-provided model LAR (Reference 6.2) that included the clarification of this Frequency Example, and a revised model for the No Significant Hazards Consideration was later provided (Reference 6.3). While the majority of the TSTF-475 and model LAR subject matter is applicable only to NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6), this Frequency Example clarification was described as applicable also to NUREG-1430 (B&W), NUREG-1431 (Westinghouse), and NUREG-1432 (CE). The Federal Register notices in References 6.5 and 6.6 announced the availability of the TS improvement through the Consolidated Line Item Improvement Process (CLIIP). The proposed changes are consistent with References 6.3 and 6.4. contains a marked-up version of the TS showing the proposed change.
Supporting changes to the TS Bases will be made in accordance with the TS Bases Control Program. Attachment 3 provides the marked-up TS Bases pages. The TS Bases mark-up pages are being submitted for information only.
3.0 TECHNICAL EVALUATION
The change to Example 1.4-3 in Section 1.4 Frequency makes it clear that the 1.25 provision in SR 3.0.2 is equally applicable to time periods specified in the FREQUENCY column and in NOTES in the SURVEILLANCE column. The revised Example is being made consistent with the definition of specified Frequency provided in the second paragraph of Section 1.4. This paragraph states:
The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The
ATTACHMENT 1 Evaluation of Proposed Changes Page 3 "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.
As made clear in the second sentence above, the specified Frequency includes time periods discussed in Notes in the SURVEILLANCE column, in addition to time periods listed in the FREQUENCY column. Therefore, the provisions of SR 3.0.2 (which permit a 25% grace period to facilitate surveillance scheduling and avoid plant operating conditions that may not be suitable for conducting the test) also apply to the time periods listed in Notes in the SURVEILLANCE column. This is because SR 3.0.2 states that The specified Frequency (emphasis added) for each SR is met if the Surveillance is performed within 1.25 times the interval specified.
Example 1.4-3 is revised to be consistent with the above statements. The Example currently explicitly recognizes that the 25% extension allowed by SR 3.0.2 is applicable to the time period listed in the FREQUENCY column, but it does not explicitly recognize that the SR 3.0.2 extension is applicable to the time period listed in the NOTE in the SURVEILLANCE column.
The change to the Example provides this explicit recognition by copying the phrase (plus the extension allowed by SR 3.0.2) in two additional portions of the discussion for this Example.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, Technical Specifications This regulation requires that the TS include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls.
CEG has determined that the proposed change clarifying the applicability of Use and Application of Surveillance Requirement notes is consistent with the regulatory requirements and criteria described above.
4.2 Precedent This change is consistent with multiple other power plants TS changes performed during implementation of TSTF-475 Revision 1, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action. Reference 6.4 documents Exelons previously-approved license amendment that modified this Example for BWR/4 and BWR/6 plants under NUREG-1433 and NUREG-1434.
4.3 No Significant Hazards Consideration CEG requests adoption of TSTF-475 Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action," an approved change to the Improved Standard Technical Specifications (ISTS) into the Braidwood Station (BRW) Units 1 and 2; Byron Station (BYR)
ATTACHMENT 1 Evaluation of Proposed Changes Page 4 Units 1 and 2; Calvert Cliffs Nuclear Power Plant (CAL) Units 1 and 2; and R. E. Ginna Nuclear Power Plant (GIN) Unit 1 Technical Specifications (TS). The proposed change would revise the Example 1.4-3 in Section 1.4 Frequency to clarify the applicability of the 25% allowance of SR 3.0.2 to time periods discussed in NOTES in the SURVEILLANCE column as well as to time periods in the FREQUENCY column by adding a phrase referencing the allowed 25%
extension in two additional places in the discussion for Example 1.4-3.
CEG has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change to revise Example 1.4-3 in Section 1.4 Frequency clarifies the applicability of the 1.25 surveillance test interval extension. There are no physical plant modifications associated with this change. The proposed amendment would not alter the way any structure, system, or component (SSC) functions and would not alter the way the plant is operated. As such, the proposed amendment would have no impact on the ability of the affected SSCs to either preclude or mitigate an accident. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The clarification of Example 1.4-3 in Section 1.4 Frequency would not change the design function or operation of the SSCs involved and would not impact the way the plant is operated. As such, the proposed change would not introduce any new failure mechanisms, malfunctions, or accident initiators not already considered in the design and licensing bases. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The clarification of Example 1.4-3 in Section 1.4 Frequency is an editorial change made to provide consistency with other discussions in Section 1.4. There are no physical plant modifications associated with the proposed amendment. The proposed amendment would not alter the way any SSC functions and would not alter the way the plant is operated. The proposed amendment would not introduce any new uncertainties or change any existing uncertainties associated with any safety limit. The proposed amendment would have no
ATTACHMENT 1 Evaluation of Proposed Changes Page 5 impact on the structural integrity of the fuel cladding, reactor coolant pressure boundary, or containment structure. The proposed amendment would not degrade the confidence in the ability of the fission product barriers to limit the level of radiation to the public.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, CEG concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
S The proposed amendment is confined to changes to the format of the license or permit or otherwise makes editorial, corrective or other minor revisions. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
ATTACHMENT 1 Evaluation of Proposed Changes Page 6
6.0 REFERENCES
6.1 TSTF-475 Revision 1, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action,. (ADAMS Accession No. ML071420428) 6.2 NRC Notice of Availability of Model Application Concerning Technical Specification Improvement To Revise Control Rod Notch Surveillance Frequency, Clarify SRM Insert Control Rod Action, and Clarify Frequency Example (Accession No. ML073050017) 6.3 NRC Notice of Availability of Revised Model Proposed No Significant Hazards Considerations Determination for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-475, Revision 1, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action" (ADAMS Accession No. ML101030613) 6.4 NRC Letter dated August 11, 2009,
Subject:
Clinton Power Station, Unit No.1; Dresden Nuclear Power Station, Units 2 And 3; Lasalle County Station, Units 1 And 2; Peach Bottom Atomic Power Station, Units 2 And 3; And Quad Cities Nuclear Power Station, Units 1 And 2 -Issuance Of Amendments Re: Application For Technical Specification Change Regarding Revision Of Control Rod Notch Surveillance Test Frequency, Clarification Of Source Range Monitor Insert Control Rod Action, And Clarification Of A Frequency Example Using The Consolidated Line Item Improvement Process (ADAMS Accession No. ML091270818) 6.5 Notice of Availability of Model Application Concerning Technical Specification Improvement to Revise Control Rod Notch Surveillance Frequency, Clarify SRM Insert Control Rod Action, and Clarify Frequency Example, published in Federal Register/Vol.
72, No. 218, November 13, 2007.
6.6 Notice of Availability of Revised Model Proposed No Significant Hazards Consideration Determination for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-475, Revision 1, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action, published in Federal Register/Vol. 75, No. 101, May 26, 2010.
ATTACHMENT 2a BRAIDWOOD STATION UNITS 1 And 2 Docket Nos. 50-456 and 50-457 Facility Operating License Nos. NPF-72 and NPF-77 MARK-UP OF TECHNICAL SPECIFICATIONS PAGE
Frequency 1.4 BRAIDWOOD UNITS 1 & 2 1.4 5 Amendment 98 1.4 Frequency EXAMPLES (continued)
EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
NOTE-----------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 25% RTP.
Perform channel adjustment.
7 days The interval continues, whether or not the unit operation is
< 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches 25% RTP to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power 25% RTP.
Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
(plus the extension allowed by SR 3.0.2)
(plus the extension allowed by SR 3.0.2)
ATTACHMENT 2b BYRON STATION UNITS 1 AND 2 Docket Nos. 50-454 and 50-455 Facility Operating License Nos. NPF-37 and NPF-66 MARK-UP OF TECHNICAL SPECIFICATIONS PAGE
Frequency 1.4 BYRON UNITS 1 & 2 1.4 5 Amendment 106 1.4 Frequency EXAMPLES (continued)
EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
NOTE-----------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 25% RTP.
Perform channel adjustment.
7 days The interval continues, whether or not the unit operation is
< 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches 25% RTP to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power 25% RTP.
Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
(plus the extension allowed by SR 3.0.2)
(plus the extension allowed by SR 3.0.2)
ATTACHMENT 2c CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 Docket Nos. 50-317 and 50-318 Facility Operating License Nos. DPR-53 and DPR-69 MARK-UP OF TECHNICAL SPECIFICATIONS PAGE
Frequency 1.4 1.4 Frequency CALVERT CLIFFS - UNIT 1 1.4-4 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201 EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
NOTE ----------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after t 25% RTP.
Perform channel adjustment.
7 days The interval continues, whether or not the unit operation is < 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches t 25% RTP to perform the Surveillance.
The Surveillance is still considered to be performed within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power t 25% RTP.
Once the unit reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
(plus the extension allowed by SR 3.0.2)
(plus the extension allowed by SR 3.0.2)
ATTACHMENT 2d R.E. GINNA NUCLEAR POWER PLANT UNIT 1 Docket No. 50-244 Facility Operating License No. DPR-18 MARK-UP OF TECHNICAL SPECIFICATIONS PAGE
Frequency 1.4 The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").
This type of Frequency does not qualify for the 1.25 times the stated Frequency extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to < 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25%
RTP.
EXAMPLE 1.4-3 FREQUENCY BASED ON SPECIFIED CONDITION SURVEILLANCEREQUIREMENTS SURVEILLANCE FREQUENCY
- NOTE -
Required to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after t25% RTP.
Perform channel adjustment.
7 days The interval continues, whether or not the plant operation is < 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power reaches t25% RTP to perform the Surveillance. The Surveillance is still considered to be performed within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day (plus the extension allowed by SR 3.0.2) interval, but operation was
< 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with power t25% RTP.
Once the plant reaches 25% RTP, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval, there would then be a failure to perform a Surveillance within the specified Frequency and the provisions of SR 3.0.3 would apply.
R.E. Ginna Nuclear Power Plant 1.4-3 Amendment 80 (plus the extension allowed by SR 3.0.2)
(plus the extension allowed by SR 3.0.2)
ATTACHMENT 1 Evaluation of Proposed Changes ATTACHMENT 3a BRAIDWOOD STATION UNITS 1 And 2 Docket Nos. 50-456 and 50-457 Facility Operating License Nos. NPF-72 and NPF-77 MARK-UP OF TECHNICAL SPECIFICATIONS BASES PAGE
- For Information Only -
SR Applicability B 3.0 BRAIDWOOD UNITS 1 & 2 B 3.0 21 Revision 141 BASES SR 3.0.1 (continued)
Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.
Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..."
interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers unit operating conditions that may not be suitable for conducting the Surveillance (e.g.,
transient conditions or other ongoing Surveillance or maintenance activities).
The specified Frequency consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.
ATTACHMENT 3b BYRON STATION UNITS 1 AND 2 Docket Nos. 50-454 and 50-455 Facility Operating License Nos. NPF-37 and NPF-66 MARK-UP OF TECHNICAL SPECIFICATIONS BASES PAGE
- For Information Only -
SR Applicability B 3.0 BYRON UNITS 1 & 2 B 3.0 21 Revision 124 BASES SR 3.0.1 (continued)
Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.
Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..."
interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers unit operating conditions that may not be suitable for conducting the Surveillance (e.g.,
transient conditions or other ongoing Surveillance or maintenance activities).
The specified Frequency consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.
ATTACHMENT 3c CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 Docket Nos. 50-317 and 50-318 Facility Operating License Nos. DPR-53 and DPR-69 MARK-UP OF TECHNICAL SPECIFICATIONS BASES PAGES
- For Information Only -
SRApplicability
B3.0
BASES
CALVERTCLIFFSUNITS1&2
B3.021
Revision62
SR3.0.2
SurveillanceRequirement3.0.2establishestherequirements
formeetingthespecifiedFrequencyforSurveillancesand
anyRequiredActionwithaCompletionTimethatrequiresthe
periodicperformanceoftheRequiredActionona"onceper.
.."interval.
WhenaSection5.5,ProgramsandManuals,specification
statesthattheprovisionsofSR3.0.2areapplicable,a25%
extensionofthetestinginterval,whetherstatedinthe
specificationorincorporatedbyreference,ispermitted.
SurveillanceRequirement3.0.2permitsa25%extensionof
theintervalspecifiedintheFrequency.Thisextension
facilitatesSurveillanceschedulingandconsidersplant
operatingconditionsthatmaynotbesuitableforconducting
theSurveillance(e.g.,transientconditionsorother
ongoingSurveillanceormaintenanceactivities).
The25%extensiondoesnotsignificantlydegradethe
reliabilitythatresultsfromperformingtheSurveillanceat
itsspecifiedFrequency.Thisisbasedontherecognition
thatthemostprobableresultofanyparticularSurveillance
beingperformedistheverificationofconformancewiththe
SRs.TheexceptionstoSR3.0.2arethoseSurveillancesfor
whichthe25%extensionoftheintervalspecifiedinthe
Frequencydoesnotapply.Theseexceptionsarestatedin
theindividualSpecifications.ExamplesofwhereSR3.0.2
doesnotapplyaretheContainmentLeakageRateTesting
Programrequiredby10CFRPart50,AppendixJ,andthe
inservicetestingofpumpsandvalvesinaccordancewiththe
applicableAmericanSocietyofMechanicalEngineers
OperationandMaintenanceCode,asrequiredby10CFR
50.55a.Theseprogramsestablishtestingrequirementsand
Frequenciesinaccordancewiththerequirementsof
regulations.TheTechnicalSpecificationscannotinandof
themselves,extendatestintervalspecifiedinthe
regulationsdirectlyorbyreference.
AsstatedinSR3.0.2,the25%extensionalsodoesnotapply
totheinitialportionofaperiodicCompletionTimethat
requiresperformanceona"onceper..."basis.The25%
extensionappliestoeachperformanceaftertheinitial
performance.TheinitialperformanceoftheRequired
The specified Frequency consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.
ATTACHMENT 3d R.E. GINNA NUCLEAR POWER PLANT UNIT 1 Docket No. 50-244 Facility Operating License No. DPR-18 MARK-UP OF TECHNICAL SPECIFICATIONS BASES PAGE
- For Information Only -
SR Applicability B 3.0 B 3.0-15 Revision 98 R.E. Ginna Nuclear Power Plant Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary plant parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..." interval.
SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).
The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply.
These exceptions are stated in the individual Specifications. The requirements of regulations take precedence over the TS. Therefore, when a test interval is specified in the regulations, the test interval cannot be exceeded by TS, and the SR includes a Note in the Frequency stating, "SR 3.0.2 is not applicable." An example of an exception when the test interval is not specified in the regulations is the Note in the Containment Leakage Rate Testing Program, "SR 3.0.2 is not applicable." This exception is provided because these programs already includes extension of test intervals.
The specified Frequency consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.