NRC Generic Letter 1989-14
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON. D. C. 20555 August 21, 1989 TO: ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR OPERATING
LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS
SUBJECT: LINE-ITEM IMPROVEMENTS IN TECHNICAL-SPECIFICATIONS - REMOVAL OF THE
3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GENERIC LETTER 89-44)
Specification 4.0.2 of the Standard Technical Specifications allows surveil- lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur- veillance interval.
A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur- veillance intervals. Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25- percent allowance to extend surveillance intervals. The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.
Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure. Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.
Sincerely, J mes 6. Partlow A sociate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the
3.25 Limit of Extending Surveillance Intervals
2. List of Most Recently Issued NRC Generic Letters A
2 l5
Enclosure 1 GUIDANCE FOR THE PREPARATION OF A LICENSE AMENDMENT REQUEST TO
REMOVE THE 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS
BACKGROUND
Specification 4.0.2 of the Standard Technical Specifications permits surveil- lance intervals to be extended up to 25 percent of the specified interval.
This extension facilitates the scheduling of surveillance activities and allows surveillances to be postponed when plant conditions are not suitable for con- ducting a surveillance, for example, under transient conditions or other ongo- ing surveillance or maintenance activities. Specification 4.0.2 also limits extending surveillances so that the combined time interval for any three con- secutive surveillance intervals shall not exceed 3.25 times the specified sur- veillance interval. The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent.
Commmonwealth Edison Company (CECo) submitted a lead-plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.25 limit for surveil- lances that are performed during a refueling outage and are specified with an
18-month surveillance interval. After discussions with the staff, CECo amended the proposal to remove the 3.25 limitation for all surveillances. The amended proposal was approved by the staff on a lead-plant basis. Consistent with NRC
policy, this Generic Letter provides guidance for license amendment requests to implement this line-item improvement in TS.
DISCUSSION _ _
Experience has shown that the 18-month surveillance interval, with the provi- sion to extend it by 25 percent, is usually sufficient to accommodate normal variations in the length of a fuel cycle. However, the NRC staff has routinely granted requests for one-time exceptions to the 3.25 limit on extending refuel- ing surveillances because the risk to safety is low in contrast to the alter- native of a forced shutdown to perform these surveillances. Therefore, the 3.25 limitation on extending surveillances has not been a practical limit on the use of the 25-percent allowance for extending surveillances that are performed on a refueling outage basis.
The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are perform- ed on a routine basis during plant operation. This safety benefit is incurred when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillance. Examples of this include transient plant operating conditions or conditions in which safety systems are out of ser- vice because of ongoing surveillance or maintenance activities. In such cases, the safety benefit of allowing the use of the 25-percent allowance to extend a surveillance interval would outweigh any benefit derived by limiting three con- secutive surveillance intervals to the 3.25 limit. Also, there is the adminis- trative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit. On the basis of these considerations, the staff concluded that removal of the 3.25 limit will have an overall positive impact on safety.
An acceptable alternative to the existing requirements of Specification 4.0.2 is the following:
8908210105
-2 -
performed within the
4.0.2 Each Surveillance Requirement shall be allowable extension specified surveillance interval with a maximumsurveillance interval.
not to exceed 25 percent of the specified the Bases Section of Specifica- Licensees should also propose changes to update Bases for Specification tion 4.0.2. Generic Letter 87-09 provided updated Specification 4.0.2, as provided
4.0.2. The following changes to the Bases of to reflect this change.
in Generic Letter 87-09, are shown underlined which the specified time Specification 4.0.2 establishes the limit for extended. It permits an interval for Surveillance Requirements may be interval tfofacilitate.
allowable extension of the normal surveillanceplant operating conditions surveillance scheduling and consideration of surveillance; e.g., transient that may not be suitable for conducting the activities. It conditions or other ongoing surveillance or maintenance of a fuel cycle f5F
also provides flexibility to accommodate the length outa ge and are s ec- surveillances that are performed at each retueling it Isnot intended ified with a 12-l an 18-1month surveillance interval. to extend surveil- that this provision be used repeatedly as a convenience that are not per- lance intervals beyond that specified for surveillances ot Specification 4.0.2 is formed during Tefueling outages. The limitation that the most probable based on engineering judgement and the recognition is the verification result of any particular surveillance being performedThis provision is of conformance with the Surveillance Requirements.
through surveillance sufficient to ensure that the reliability ensuredthat obtained from the activities is not significantly degraded beyond specified-surveillance interval.- --
SUMMARY
4.0.2 will remove an un- This alternative to the requirements of Specificationrequirements and will result in necessary restriction on extending surveillancenot conducive to the safe conduct a benefit to safety when plant conditions are the 3.25 limit will provide -
of surveillance requirements. The removal of for extending surveillance in- greater flexibility in the use of the provision with its use, and have a tervals, reduce the administrative burden associated positive effect on safety.
I
LIST OFRECENTLY ISSUED GENERIC LETTERS Enclosure 2 Generic Date of Letter No Subject Issuance Issued To
89-14 LINE-ITEMS TECHNICAL SPECIFI- 08/21/89 CATION IMPROVEMENT - REMOVAL ALL LICENSEES OF
OPERATING PLANTS,
OF 3.25 LIMIT ON EXTENDING APPLICANTS FOR
SURVEILLANCE INTERVALS OPERATING LICENSES,
(GENERIC LETTER 89-14) AND HOLDERS OF
CONSTRUCTION PERMITS
89-13 GENERIC LETTER 89-13 7/18/89 SERVICE WATER SYSTEMS LICENSEES TOALL
PROBLEMS AFFECTING POWER REACTORS
SAFETY-RELATED EQUIPMENT BWRS, PWRS, AND
VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
89-12 GENERIC LETTER 89-12: 7/6/89 OPERATOR LICENSING LICENSEES TO ALL
EXAMINATIONS POWER REACTORS
BWRS, PWRS. AND
VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
89-11 GENERIC LETTER 89-11: 6/30/89 RESOLUTION OF GENERIC ISSUE ALL BWR PLANTS I
101 'BOILING WATER ALL LISTINGS
REACTOR APPLICABLE TO
WATER LEVEL REDUNDANCY' GENERIC LETTERS &
VENDORS, ETC.
89-10 GENERIC LETTER 89-10: 6/28/89 SAFETY-RELATED MOTOR-OPERATED LICENSEES TO ALL
VALVE TESTING ANDSURVEILLANCE POWER REACTORS,
BWRS, PWRS, AND
VENDORS IN ADDITION
TO GENERAL CODES
APPLICABLE TO
GENERIC LETTERS
89-09 ASMESECTION III COMPONENT 5/8/89 REPLACEMENTS ALL HOLDERS OF LIGHT
WATER REACTOR
OPERATING LICENSES
89-08 ISSUANCE OF GENERIC LETTER 5/2/89
89-08: EROSION/CORROSION - LICENSEES TOALL
INDUCED PIPE WALL THINNING - POWER REACTORS,
10 CFR550.54(f) BWRS, PWRS, AND
VENDORS IN ADDITION
TOGENERAL CODES
APPLICABLE TO
GENERIC LETTERS
UNITED STATES
NUCLEAR REGULATORY COMMISSION FIRST CLASS MAIL
WASHINGTON, D.C. 20555 POSTAGE SEES PAID
OFFICIAL BUSINESS PERMIT No. 6.6 PENALTY FOR PRIVATE USE, $300
August 21, 1989
-' TO: ALL LICENSEELI OPERATING PLANTS, APPLICANTS EVE OPERATING
LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS
SUBJECT: LINE-ITEM IMPROVEMENTS IN TECHNICAL SPECIFICATIONS - REMOVAL OF THE
3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GENERIC LETTER 89-14)
Specification 4.0.2 of the Standard Technical Specifications allows surveil- lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur- veillance interval.
A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur- veillance intervals. Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25- percent allowance to extend surveillance intervals. The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.
Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure. Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.
Sincerely, Original signed by James G.Partlow James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the
3.25 Limit of Extending Surveillance Intervals
2. List of Most Recently Issued NRC Generic Letters Distribution:
See Attached Concurrence:
Te following individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR:
TGDunning OTSB:DOEA; RLEmch, OTSB:DOEA; EJButcher, C:OTSB:DOEA; BCalure, TECH EDIT6R; CHBerlinger, C:GCB:DOEA; CERossi, D:DOEA:NRR; FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR, JHSniezek, DD:NRR
In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director, NRR, ted August , 1989, CRGR waived their review of this Generic Letter.
Jose A. Calvo, Chief ,.1<
X *See previous concurrence Technical Specifications Branch AD:ADP:NR
JGi'artlow
08/~-'/89 ADT
F8i lia i
FlIEtcoEN Er, py'-;
TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT: LINE-ITEM IMPROVEMENTS IN TECHNICAL SPECIFICATIONS - REMOVAL OF THE
3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (Generic Letter 89- )
Specification 4.0.2 of the Standard Technical Specifications allows surveil- lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur- veillance interval.
A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur- veillance intervals. Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25- percent allowance to extend surveillance intervals. The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.
Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure. Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.
Sincerely, James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
As stated Distribution:
See Attached Concurrence:
The following individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR:
TGDunning, OTSB:DOEA; RLEmch, OTSB:DOEA; EJButcher, C:OTSB:DOEA; BCalure, TECH EDITOR; CHBerlinger, C:GCB:DOEA; CERossi, D:DOEA:NRR; FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR. JHSniezek, DD:NRR
In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director, NRR, dated August31, 1989, CRGR waived their review of this Generic Letter.
A;Jose A. Calvo, Chief Technical Specifications Branch AD:ADP:NRR ADT v JGPartlow FMir 7d q
7 O8/ /89 08 ft"9 g ~ S
' 'Generic Letter 89-14 i<. August 21, 1989 Distribution:
TEhurley JACalvo PDR
JHSniezek CHBerlinger OTSB Members FJMiraglia CJHaughney OTSB R/F
JGPartlow JLieberman DOEA R/F
SAVarga BDLiaw ~&-~Central Files DMCrutchfield CERossi JWRoe GCLainas ELdordan JHConran FJCongel CIGrimes FGillesple WGKennedy JZwolinski MGMalsch GMHolahan SATreby ACThadani JERichardson HSmith
P_
O: AL LAugust 21, 1989 TO: ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOVOPERATING
LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS
SUBJECT: LINE-ITEM IMPROVEMENTS IN TECHNICAL SPECIFICATIONS - REMOVAL OF THE
3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GENERIC LETTER 89-14)
Specification 4.0.2 of the Standard Technical Specifications allows surveil- lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur- veillance interval.
A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur- veillance intervals. Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25- percent allowance to extend surveillance intervals. The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.
Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure. Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.
Sincerely, Original signed by James G.Pafflow James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the
3.25 Limit of Extending Surveillance Intervals
2. List of Most Recently Issued NRC Generic Letters Distribution:
See Attached Concurrence:
lihrleT1TiTng individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR:
TGDunning, OTSB:DOEA; RLEmch, OTSB:DOEA; EJButcher, C:OTSB:DOEA; BCalure, TECH EDITOR; CHBerlinger, C:GCB:DOEA; CERossi, D:DOEA:NRR; FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR, JHSniezek, DD:NRR
In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director,
?HRR, ted August , 1989, CRGR waived their review of this Generic Letter.
\L\Jose A. Calvo, Chief
= *See previous concurrence Technical Specifications Branch AD:ADP:NRA. ADT *
JGPartlow F r4 ia
0B/'~-/89 e
1. I
August 21, 1989 MEMORANDUM FOR: All Project Managers FROM: James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation SUBJECT: A LINE-ITEM TECHNICAL SPECIFICATION IMPROVEMENT - REMOVAL OF
3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GENERIC
LETTER 89-14)
Enclosed is Generic Letter 89-14 which is being sent to all power reactor licensees and applicants. It provides guidance for the preparation of a license amendment request to implement a line-item improvement in Technical Specifications (TS) to remove the 3.25 limit on extending surveillance inter- vals. Any request for this change in TS is voluntary.
It is intended that Project Managers will review and process proposed amend- ments conforming to the guidance of the Generic Letter. Generally, it should not be necessary to consult or to obtain review assistance from the Technical Specifications Branch unless the proposed amendment deviates from the Generic Letter guidance.
Enclosed is a model Safety Evaluation Report (SER) that was prepared by the Technical Specifications Branch. This model SER should facilitate your prepara- tion of a license amendment to implement the line-item improvement in TS.
If you should have any questions on the Generic Letter or model SER, contact Tom Dunning, OTSB, on extension 21189. The Lead Project Manager for this task is Harley Silver on extension 21470. Harley will assist you in the preparation of a NSHC prenotice for a proposed amendment conforming to the Generic Letter and he should be included on concurrence for the license amendment package.
Original signed by JJamesS artow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
Generic Letter 89-14 Model SER
cc wfenclosures:
J. Taylor H. Thompson Division Directors, KRR
Associate Directors, NRR
Project Directors, NRR DISTRIBUTION
Regional Administrators tieiniTR77Ms J. Conran, CRGR NRC PDR
H. Silver OTSB/RF
C. Berlinger, DOEA T. Dunning S. Treby, OGC
(3.25 memo) *See prior concurrence
- OTSB:DOEA *OTSB:DOEA *C:OTSB:DOE AD:ADP R
TGDunning* RLEmch* JACalvo* JGPartlo
08/14/89 08/14/89 08/14/89 O8A /89 J-00.