View source for PLA-5443, Proposed Amendment No. 246 to License NPF-14 and Proposed Amendment No. 210 to License NPF-22: Application for Technical Specification Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process

{{Adams
| number = ML021060278
| issue date = 04/02/2002
| title = Proposed Amendment No. 246 to License NPF-14 and Proposed Amendment No. 210 to License NPF-22: Application for Technical Specification Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process
| author name = Byram R
| author affiliation = PPL Susquehanna, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000387, 05000388
| license number = NPF-014, NPF-022
| contact person = 
| case reference number = PLA-5443
| document type = Letter type:PLA, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 21
| project = 
| stage = Request
}}

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PPL Susquehanna, LLC Robert G. Byram                      Two North Ninth Street               1  ,I.l      '-T Senior Vice President and             Allentown, PA 18101-1179 Chief Nuclear Officer Tel. 610.774.7502 Fax 610.774.6092 rgbyram@pplweb.com APR 2     2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NO. 246 TO LICENSE TO NPF-14 AND PROPOSED AMENDMENT NO. 210 LICENSE NPF-22: APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCES USING THE CONSOLIDATED                                       Docket No. 50-387 LINE ITEM IMPROVEMENT PROCESS                                                        and 50-388 PLA-5443 is In accordance with the provisions of 10 CFR 50.90, PPL Susquehanna, LLC for Susquehanna submitting a request for an amendment to the Technical Specifications Units 1 and 2.
for missed The proposed amendment would modify Technical Specification requirements surveillances in SR 3.0.3.
confirmation Attachment 1 provides a description of the proposed change, the requested existing of applicability, and plant-specific verifications. Attachment 2 provides the 3
Technical Specification pages marked up to show the proposed change. Attachment of the provides revised "Camera Ready" TS pages. Attachment 4 provides a summary regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show the proposed change (for information only).
We request approval of the proposed License Amendment by June 30, 2002, with the amendment being implemented within 60 days following approval. The NRC recently approved similar submittals for Fermi 2 and Point Beach.

Document Control Desk PLA-5443 is being In accordance with 10CFR 50.91, a copy of this application, with attachments, provided to the designated Pennsylvania Official.
D. L. Filchner at If you have any questions regarding this submittal, please contact Mr.
(610) 774-7819.
Sincerely, cc:    NRC Region I Mr. S. L. Hansell, NRC Sr. Resident Inspector Mr. T. G. Colburn, NRC Sr. Project Manager Mr. D. J. Allard, DEP

BEFORE THE BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of PPL Susquehanna, LLC:                                                          Docket No. 50-3 87 PROPOSED AMENDMENT NO. 246 TO LICENSE NPF-14: APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCES USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS UNIT NO. 1 Licensee, PPL Susquehanna, LLC, hereby files a Proposed Amendment No. 246 in support of a revision to its Facility Operating License No. NPF-14 dated July 17, 1982.
This amendment involves a revision to the Susquehanna SES Unit 1 Technical Specifications.
PPL Susquehanna, LLC By:
                                        -eff. Byr nm Sr*.      esident and Chief Nuclear Officer Sworn to and subscribed before me This -201 day of           L    2002.                              Notarial Seal Nancy J. Lannen, Notary Public Allentown, Lehigh County My Commission Expires June 14, 2004

BEFORE THE BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of PPL Susquehanna, LLC                                                          Docket No. 50-388 PROPOSED AMENDMENT NO. 210 TO LICENSE NPF-22: APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MISSED SURVEILLANCES USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS UNIT NO. 2 Licensee, PPL Susquehanna, LLC, hereby files a Proposed Amendment No. 210 in support of a revision to its Facility Operating License No. NPF-22 dated March 23, 1984.
This amendment involves a revision to the Susquehanna SES Unit 2 Technical Specifications.
PPL Susquehanna, LLC By:
Sr.              and Chief Nuclear Officer Sworn to and subscribe&#xfd; before me Notarial Seal this ;2-#j A day of &#xa3;4L,2002.                           Nan7 J. Lannen, Notary Public AlIentown, Lehigh County My Commission Expires June 14, 2004

Attachment 1 Description, Applicability, and Verification of the Proposed Change

Attachment 1 to PLA-5443 Page 1 of 3 Description, Applicability, and Verification of the Proposed Change

==1.0 DESCRIPTION==

In accordance with 10 CFR 50.90, PPL Susquehanna, LLC (PPL) proposes to revise the Susquehanna Steam Electric Station (SSES) Units 1 and 2 Technical Specifications (TS).
The proposed amendment would modify TS requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3.
The proposed changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF - 358, Revision 5, as modified by FederalRegister Notice 66FR32400, of June 14, 2001, and in response to public comments. The availability of this TS improvement was published in the FederalRegister on September 28, 2001 (66FR49714) as part of the Consolidated Line Item Improvement Process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation PPL has reviewed the Safety Evaluation (SE) dated June 8, 2001 as part of the CLIIP.
This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF - 358. PPL has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to SSES Units 1 and 2 and justify this amendment for the incorporation of the changes to the SSES TS.
2.2 Optional Changes and Variations PPL is not proposing any variations or deviations from the TS changes described in TSTF - 358 Revision 6 or the NRC staffs model SE dated June 8, 2001.

Attachment 1 to PLA-5443 Page 2 of 3

==3.0 REGULATORY ANALYSIS==

3.1 No Significant Hazards Consideration Determination PPL has reviewed the proposed No Significant Hazards Consideration (NSHC) determination published in the FederalRegister as part of the CLIIP. PPL has concluded that the proposed NSHC determination presented in the FederalRegister notice is applicable to SSES and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on September 28, 2001 for this TS improvement, plant-specific verifications were performed as follows:
PPL has established TS Bases for SR 3.0.3 which state that 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, but only for the performance of missed surveillances.
The modification will also include changes to the Bases for SR 3.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that PPL is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance.
The Bases changes also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases changes state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases changes also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases changes state that all missed surveillances will be placed in the PPL Corrective Action Program. Finally, PPL has a Bases Control Program consistent with Section 5.5 of the STS.

Attachment 1 to PLA-5443 Page 3 of 3 4.0 ENVIRONMENTAL EVALUATION PPL has reviewed the environmental evaluation included in the model SE dated June 8, 2001 as part of the CLIIP. PPL has concluded that the staff's findings presented in that evaluation are applicable to SSES and the evaluation is hereby incorporated by reference for this application.

Attachment 2 Technical Specification Markups (Units 1 & 2)

SR Applicability 3.0 3.0    SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR   3.0.1          SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall e failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR   3.0.2          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 condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR    3.0.3         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 hours or up to the limit of the specified Frequency, whichever is         This delay period is permitted to allow performance of the
-r-S-rF -3 6-          Surveillance.
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 (continued)'
SUSQUEHANNA - UNIT 1                   3.0-4                         Amendment 178

SR Applicability 3.0 3.0   SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR   3.0.1         SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2           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 condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per . . ." basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3           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 hours or up to the limit of the specified Frequency, whichever is (       T& delay
                                                                -.his period is permitted to allow performance of thelq      ,. e I-S TF -38         Surveillance.4 w               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 (continued)
SUSQUEHANNA - UNIT 2                  3.0-4                         Amendment 151

TSTF - 358 INSERT 3 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed.

Attachment 3 "Camera Ready" Technical Specifications (Units 1&2)

SR Applicability 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1             SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.
Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2             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 condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3             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 hours 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 hours and the risk impact shall be managed.
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 (continued)
SUSQUEHANNA - UNIT 1                TS / 3.0-4                               Amendment

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY SR 3.0.1               SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.
Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2               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 condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3                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 hours 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 hours and the risk impact shall be managed.
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 (continued)
SUSQUEHANNA  - UNIT 2                 TS / 3.0-4                               Amendment

Attachment 4 List of Regulatory Commitments

Attachment 4 to PLA-5443 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following Table identifies those actions committed to by PPL Susquehanna, LLC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. D. L. Filchner at (610) 774-7819.
REGULATORY COMMITMENTS                             DUE DATE/EVENT PPL will establish the Technical Specification Bases for     To be implemented with SR 3.0.3 as adopted with the applicable license amendment. amendment.

Attachment 5 TS Bases Markups

SR Applicability B 3.0 BASES ri&#x17d;D SR   3.0.3         period of up to 24 hoursL      r<iHED orup to the limit of the specified (continued)     Frequency, whichever is              , applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
with   a  Fre   uency based noton time rWhen a $Lrveillanc pecified u itconditions r operati'~al interval* but upon                                     perfomed when is   discov   red not toN ave been period      f 24 hours
                    @ituations\              aIl   ws the ful~k delay s *ecified,       3.0.3 Surveilla" e.*
to&deg;erform t o0 p  *vides   a  til*   limit for ompletion          f
_SR 3. *.3 also           become   app    ilcable asconsequence Survei lqances  tha by Required Actions.
MODEL cha ges imposed 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.
5'F  - SO If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the (continued)
SUSQUEHANNA - UNIT 1                     B 3.0-13                                Revi si on 0

SR Applicability B 3.0 BASES SR   3.0.3               period of up to 24 hours oup to the limit of the specified (continued)           Frequency, whichever is          .,  applies from the point in time that   it  is discovered  that  the   Surveillance has not been performed in accordance      with   SR  3.0.2, and not at the time that   the  specified Frequency     was  not met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When     Surveillance with a Frequency interv s, but up specifie unit cc situatio s, is dis vered not o hav(
Recifie ,SR 3.0.3 llows the              11 c tperform he Survei ance.
SR 0.3 also rovides a ime limit Survee lances at become plicable MODE c nges imp ed by Req red Actq 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 used as .ian operational convenience to extend Sll*-* *-}Surveillanceintended to beintervals tISET-        2-           If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the (continued)
SUSQUEHANNA - UNIT 2                         B 310-13                              Revision 0

TSTF - 358 INSERT 1 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 when specified, 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 missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
TSTF - 358 INSERT 2 While up to 24 hours or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed 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.
The risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management actionthresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.}}