ML19332C429

Proposed Tech Specs 3/4.3.10.a & B & Bases Re self-test Sys, Note to 3/4.6.1 Concerning Verification of valves,5.2.3 on Design Features of Secondary Containment & Surveillance Requirement 4.0.2

ML19332C429
Person / Time
Site:	Clinton
Issue date:	11/20/1989
From:	ILLINOIS POWER CO.
To:
Shared Package
ML19332C425	List: ML19332C424 ML19332C429
References
U-601548, NUDOCS 8911280114
Download: ML19332C429 (17)

Text

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INSTRUMENTATION -

3/4.3.10 NUCLEAR SYSTEM PROTECTION SYSTEM - SELF TEST SYSTEM- ,

-LIMlTING CONDITION FOR OPERATION

-3.3.10 The SELF TEST SYSTEM (STS) of the Nuclear System Protection System l shall be OPERABLE and operating in the fully automatic mode.."

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, 4, and 5. ,

ACTION: ,

a. With-the STS not operating in the fully automatic mode initiate correctivel action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the STS to automatic operation for the-maximum number-of divisions available.

b .- If the-STS is not restored to fully automatic operation within 30 days, be in at least NOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN t within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

- The provisions of Specification 3.0.4 are not applicable.

k . REPt. ACE WITH ATTACHED SURVEILLANCE REQUIREMENTS:

.4.3.10 Status indications of the STS shall be obtained at.least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, whenever the STS is operating in the fully or partially automatic mode, s

• The STS may be periodically taken out of the fully automatic mode of operation for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for the purpose of performing surveillance testing and pre-ventative or corrective maintenance to satisfy technical specifica~ tion requirements for those components the STS is desionad to monitor.

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I a. With the STS not operating in the fully automatic mode, initiate 1 action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the STS to automatic operation n -for'the maximum number of divisions available, and W u

1. .In OPERATIONAL CONDITION 1, 2 or 3:

a)- Restore the STS to-fully automatic operation within 30

' days, or b) Within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 7 days thereafter, operate the STS manually to perform all i required-tests not being performed.in the automatic mode untilithe-STS is restored to fully automatic operation, I .

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;

2. In OPERATIONAL CONDITION 4 or 5:

a)' Restore the STS to fully automatic operation within 90 days, or b) Uithin the next 24. hours and at least once per 90 days ,

thereafter, operate-the STS manually to perform all  ;

required tests not being performed in the automatic-mode until the STS is restored to fully automatic  !

operation, Otherwise, suspend CORE ALTERATIONS and all operations with

• a potential for draining the reactor vessel, verify all insertable control rods to be. fully inserted and lock.the reactor mode switch in the Shutdown position within one hour.

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INSTRUMENTATION =

BASES 3/4.3.9 PLANT SYSTEMS ACTUATION INSTRUMENTATION (Continued) fluctuations are accounted for in the trip- setpoints and allowable values spect-fied for.drywell and containment pressure-high.- A 10-minute minimum, 13-minute maximum time delay exists between initiation of LPCI and containment spray actuation. A high reactor water level, level 8, signal will actuate the feed-water system / main turbine. trip system. The suppression pool makeup system is automatically initiated on a low low suppression pool water level signal with a .

concurrent LOCA signal or following a specified time delay after receipt of a LOCA signal.

3/4.3.10 NUCLEAR SYSTEM PROTECTION SYSTEM - SELF TEST SYSTEM This specification provides the limiting conditions for operation necessary to

' preserve the STS's ability to perform its intended function of detecting and determining the location of a fault in the functional NSPS.

The Self Test System (STS) is an overlay testing and surveillance subsystem which provides the capability to continuously and automatically perform testing of all active circuitry within the NSPS panels, essential to the safe shutdown of the' reactor. - The primary purpose of the STS is to enhance the availability of the NSPS by optimizing the~ time to detect and determine the location of a failure in the functional system. Each of the four NSPS cabinets, with one cabinet associated with each of the four Class IE powered NSPS divisions, con-p tains its pwn controller (STC). The STS will be used for post-maintenance test-ing and to augment. conventional testing methods which include CHANNEL CHECKS, l ' CHANNEL FUNCTIONAL TESTS, CHANNEL CALIBRATIONS. RESPONSE TIME TESTS.and LOGIC l

! SYSTEM FUNCTIONAL TESTS.;FThe overall availability of the NSPS with the STS'JL-rtotally inoperable for up to 30 days, is shown by analysis to be adequate. ..

Requiring the STS to be in operation in a partially automatic mode whenever possible provides further enhancement of NSPS availability.jr .

INSERT HEW, ADDITION AL PARAGRAPH ( ATTACHED)-

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"*~ LS-87-056 Page 12 of 12 l Under the provisions of the ACTION statement, with the STS inoperable or not

-operating in the fully automatic mode of operation, 30 days is allowed to )

restore the STS to fully automatic operation _during OPERATIONAL CONDITIONS 1,

.2, 3; 90 days is allowed during OPERATIONAL CONDITIONS 4, 5. Additionally,  ;

-the ACTION includes an allowance for manually operating the SIS to_ perform i testing equivalent to that which is normally performed during automatic l operation if the STS cannot be restored to fully automatic operation within  ;

the required time limits. Manual STS testing is required to be performed at least once per 7 days during OPERATIONAL CONDITIONS 1, 2, 3 and at least once ,

per 90 days during OPERATIONAL CONDITIONS 4, 5. These frequencies and the above allowed out-of service times have been shown by analysis to be acceptable for supporting adequate _overall availability of the NSPS.

Maintaining the STS in a partially automatic mode as much as possible "

(whenever it is not operating in the fully automatic mode) provides further enhancement of-the NSPS availability.

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PS-88 021 Page 1 of 4 Descriotion of Proposed Change In order to ensure PRIMARY CONTAINMENT INTEGRITY, Technical Specification 4.6.1.1.b requires verifying at least once per 31 days that all containment penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in the closed position. A note ("**") is attached to this Specification which provides relief for valves, blind flanges and deactivated automatic valves which are located inside the primary containment, steam tunnel or drywell and are locked, sealed er otherwise secured in the closed position.

According to the note, the penetrations associated with such valves or ,

flanges shall be verified to be closed during each COLD SHUTDOWN (prior to startup) except such verification need not be performed more often than once per 92 days.

Illinois Power (IP) proposes to revise the ** note by extending the provisions of the note to include two valves which are not located inside the primary containment, steam tunnel, or drywell. Specifically, the i revised note would read as follows. (See also the attached marked-up page 3/4 6 1 from the CPS. Technical Specifications.)

• • Except valves 1HG016 and 1HG017 and valves, blind flanges, and deactivated automatic valves which are: located inside the primary containment, steam tunnel, or dryvell, and are locked, sealed or otherwise secured in the closed position. These

-penetrations shall be verified closed during each COLD SHUTDOWN except such verification need not be performed more often than once per 92 days.

Justification for Proposed Changg 1.

As indicated above, the ** note allows penetrations with valves, blind flanges and deactivated automatic valves within the primary containment, steam tunnel or drywell to be verified that they are closed only durir.g plant shutdowns instead of at least once per 31 days as required by l Surveillance Requirement 4'.6.1.1.b. IP believes that the original intent of the ** note was to reduce the frequency for which certain valves or flanges (for applicable penetrations) must be verified to be closed in order to reduce personnel exposure and based on a consideration of factors L such as the probability of the valves being in the wrong position (open),

L the relative inaccessibility of the valves caused by environmental conditions existing at the valve locations, the valve function (potential flow path), valve size, etc. Based on the following discussion, IP finds that in accordance with the intent of the ** note, the provisions of the note are also applicable to valves 1HG016 and lHG017.

The primary reason for including valves 1HG016 and 1HG017 within the scope l of the ** note is to reduce personnel exposure. The valves are located in L a room (within the auxiliary building) that is adjacent to the main steam tunnel. In addition, the room atmosphere communicates directly with the

! main steam tunnel via a pipe tunnel. Radiation levels in the, room are relatively high during power operation primarily due to the proximity of the main steam lines and reactor water cicanup system pEping. The room is RFP1:GSL14

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PS 88 021 Page 2 of 4 designated as a restricted high radiation area. (Radiologically, the room is an extension of the main steam tunnel, but it is not physically included within the boundaries of the steam tunnel as depicted in the CPS Updated i Safety Analysis Report.) Verification of the position of these valves j

'during power operation results in significant exposure to plant personnel.

The proposed change would therefore result in reduced personnel exposure because the number of required entries into the room would be greatly l reduced. IP estimates that a savings of at least 10 man Rem (during the life of the plant) would result from the proposed change. Moreover, because the radiation levels in the noted room are power dependent (because ,

they result from decay of N-16 in the main steam lines), it is appropriate I to check the valve positions during shutdown conditions when radiation levels are minimal.

With respect to a consideration of the other factors previously mentioned, valves 1HC016 and 1HG017 are both 3/4 inch Class B globe valves. The valves are located on 3/4-inch test connections respectively associated with the 2-inch suction and return lines for hydrogen recombiner OHG01SA.

As test connections, the valves are not required to be manipulated to _;

operate the hydrogen recombiner. In fact, both valves are normally locked '

! closed and in addition, the test connections in which they are located are pipe capped. Since test connections are generally under procedural control,- the probability of mispositioning either valve is very low. (Test connections, vents, and drains may only be opened on an intermittent basis' <

under administrative control during power operation in accordance with Note -l (a) of Technical Specification Table 3.6.4-1, CONTAINHENT ISOLATION VALVES.) Moreover, since the test connections are situated within the secondary containment, any leakage that could occur would be within the secondary containment where the Standby Cas Treatment- System would be available to treat this leakage.

Basis For No Sienificant Hazards Consideration l According to 10CFR50.92, a proposed change to the license (Technical l Specifications) involves no significant hazards consideration if operation of the facility in accordance with the proposed change would not (1) involvo a significant increase in the probability or consequences of an i

accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

(1) The proposed change does not involve a significant increase in the probability or consequences of any accident previously evaluated.

Although valves 1HG016 and 1HG017 are assumed to be closed during accident conditions, the proposed change should not increase the likelihood of having these normally closed valves left or found in the open position due to the administrative controls placed on test connections and their infrequent use. Morcover, the proposed change does not affect the leak test requirements for the affected valves.

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'(2) The proposed change does not create the possibility of a new or '

different kind of accident from any accident previously evaluated.

Incorporating valves 1HG016 and 1HG017 into the ** note does not affect the design or operation of any component syster. or structure and therefore will not create the possibility of any new or different kind of accident.

(3) The proposed change does not involve a significant reduction in a- }

margin of safety. As noted previously, the proposed change does not

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impact'the leak rate requirements and should not involve any increase in the probability of the test connection valves being open, therefore no margin of safety with respect to containment integrity or leakage is affected,

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3/4.6.1- PRIMARY CONTAINMENT i PRIMARY CONTAINMENT INTEGRITY  !

LIMITING CONDITION FOR OPERATION j

3. 6.1.1 PRIMARY CONTAINMENT INTEGRITY shall be maintained. 1 u

APPLICABILITYi OPERATIONAL CONDITIONS 1, 2*, and 3.

ACTION:

'Without PRIMARY CONTAINMENT INTEGRITY, restore PRIMARY CONTAINMENT INTEGRITY within:1 hour or be. in at least HOT SHUT 00WN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the 'following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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-SURVEILLANCE REQUIREMENTSi

' 4. 6.1.1 PRIMARY CONTAINMENT INTEGRITY shall be demonst ated:

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a. After each closing of each penetration subject to' Type B testing, except the primary containment air locks, if opened following Type A or B test, ,

by : leak rate'. testing'the seals with gas at Pa, 9.0 psig, and verifying - 4

, that when the measured leakage rate for these seals is'added to the

• 7 ' leakage: rates determined pursuant to Surveillance Requirement 4.6.1.2.d ,

p for~all other. Type B and C penetrations, the combined leakage rate is less- ,

L ~than or equal to 0.60 La.

b. At least once per 31 days by verifying that all containment penetrations ** I not capable-of being closed by OPERABLE containment automatic isolation .

l4 valves and required to be closed during accident conditions are closed by_ "

l valves, blind flanges, or deactivated automatic valves secured-in position, except.as'provided in Table 3.6.4-l'of Specification 3.6.4.

4 c. - By verifying each primary containment air lock is in compliance with the requirements of Specification 3.6.1.3.

d. By verifying the suppression pool is in compliance with the requirements of Specification 3.6.3.1. .,

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• • Exceptava ves, blind flanges, and deactivated automatic valves which are l locatedLinside the primary containment, steam tunnel, or drywell, and are L

locked, sealed or otherwise secured in the closed position. These penetrations shall'be verif_ied closed during each COLD SHUTDOWN except such verification need not be performed more often than once per 92 days.

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L ** LS.88 043 H Page 1 of 2 Descriotion of Proposed Change Illinois Power (IP) is requesting a change to Clinton Power Station (CFS)

Technical Specification 5.2.3 to revise the vsLue for the becondary Containment minimum free volume specified by that Specificagion. The currentTechnicalSpec*,fication5.2.3valugof 2,000,000 ft for this parameter is being revised to 1,710,000 ft as indicated on the attac..ed marked up page.

Justification for Pronosed Chance During a Quality Assurance (QA) audit of the CPS Technical Specifiutions, itwasnotedthatthevalueforsecondarycontaingentminimumfreevolume specified in Specification 5.2.3 was 2,000,000 ft while the marable Upc'ated Safety Analysis Report (USAR) value was 1,710,000 ft In f t.3estigation determined

) was an initial estimatethat thesecondary for the Technical containment Specificationfree value (2,000,000N volume.

1981, the va ft}ueintheFinalSafetyAnalysisReport(FSAR)wasrevisedto i

, 1,710,000 , but due to an oversight by IP, Technical Specification 5.2.3 l wco not revised.

IP has considered the generic implications of this change and bas d on a review of values for other parameters in section 5.0 of the CPS Technical Specifications, no other discrepancies of this type were found. It ahnuld also be noted the,t the USAR value for the secondary containmen, ' minimum free volume was used in all of the applicable analyses discusses. in the USAR. Therefore, there is no impact on plant safety resulting fren this revision of the Technical Specification because the USAR is the primary document providing Citnton's design basis.

Basts For No Significant Harards Consideration According to 10CFR50.92, a proposed change to the dcense (Technical Specifications) involves no significent hazards consideration if operation of the facility in accordance with the proposed change would not (1) irvolve a significant increata in the probsbility or consequences of an i accident previously evaluated, or (2) create the possibility of a new or l differer.t kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

(1) As indicatod abon , the proposed change revisos the value in the Technical Specifications for the Secondary Containment minir.an free volume to be consistent to the USAR. Therefore, the CPS sccident l analyses are not affected and the proposed change does not involve a significant increase '.n the probability or consequences of an accident previous 1v evaluated.

(2) The proposed change does not affect the confiEuration or operation of any plant components, systems or structure. Therefore, the possibility of a new or different kind of accident is not created.

(3) As noted previously, the USAR value for the secondary containment j minimum free volume was used in all applicable analyses; therefore, 1 revising the Technicel Specification as discussed does not reduce the  !

margin of safety derived from the CPS safety analysis, i

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5 DESIGN FEATURES

SECONDARY CONTAINM

NT 5.2.3 The secondary containment consists of the fuel Building, the ECCS pump ,

rooms and the containment cas control boundary, including extension, and has a minimum free volume off2,000.000) cubic feet.

5.3 REACTOR CORE FUEL ASSEMBLIES

5.3.1 The reactor core shall contain 624 fuel assembifes with each fuel assembly containing 62 fuel rods and two water rods clad with Zircaloy-2. Each fuel rod shall have a nominal utive fuel length of 150 i'.ches. The initial core loading shall have a core average anrichment of 1.706 veight percent U-235. Reload '

fuel shall be similar in physical design to the initial core loading.

CONTROL ROD ASSEMBLIES 5.3.2 The reactor core shall contain 145 control rod assemblies, each consist-ing of a cruciform array of stainless steel tubes containing 143.70 inches of boron carbide, B.C, powder surrounded by a cruciform shaped stainless steel sheath.

5.4 REACTOR COOLANT SYSTEM DESIGN PRESSURE AND TEMPERATURE 5.4.1 The reactor coolant system is designed and shall be maintained:

a. In accordance with the code requirements specified in Section 5.2 of the FSAR, with allowance for norr:1 degradation pursuant to the applicable ~

Surveillance Requirements, b.- For a pressure of:

. 1. 1250 psig on the suction side of the recirculation pump.

2. 1650 psig from the recirculation pump discharge to the outlet side of the discharge shutoff valve.

3. 1550 psig from the discharge shutoff valve to the jet pumps.

c. For a temperature of 575'F.

VOLUME

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5.4.2 The total water and steam volume of the reactor vessel and recirculation system is approximately 16,000 cubic feet t.t a nominal steam dome saturation temperature of 549'F.

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U.601548 i~ ** LS.89 017 i Page 1 of 7 l Description of Proposed Chance

, i In accordance with the guidance of Generic Letter 89 14, "LINE. ITEM l' IMPROVEMENTS IN TECHNICAL SPECIFICATIONS REMOVAL OF THE 3.25 LIMIT ON EXTENDING SURVEILIANCE INTERVALS," Illinois Power (IP) is requesting a change ,

to Clinton Power Station (CPS) Technical Specification 4.0.2 and its associated BASES to remove the 3.25 limit on extending surveillance intervals. l The proposed wording for Specification 4.0.2 and its associated BASES, as i revised, is as follows:

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.  !

BASES 4.0.2 Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits i an allowable extension of the normal surveillance interval to facilitato surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., ,

transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18 month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the l

reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

l A copy of marked up pages from the current CPS Technical Specifications for l Specification 4.0.2 and its associated BASES is attached.

Justification for Proposed Chance CPS Technical Specification 4.0.2 permits surveillance intervals to bo 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 conducting a surveillance, for example, under transient conditions or other ongoing surveillance or maintenance activities. The existing Technical Specification 4.0.2 also limits extending surveillance intervals so that the combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval. The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent.

Industry experience has shown that the 18 month surveillance interval, with the provision 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 RFP2:CSL9

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y. Page 2 of 7 routinely granted requests for one time exceptions to the 3.25 limit on i extending 18 month surveillance intervals because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these -

surveillances. Therefore, the 3,25 limitation on extending surveillance intervals has not been a pract.ical limit for limiting the use of the 25 percent allowance for extending the intervals of surveillances that are performed on a refueling outage basis. .

i The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are performed on a routine basis during plant operstion. 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 service 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 lim!;ing three consecutive surveillance intervals to the 3.25 limit. Also,  ;

there is the administrative 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 NRC staff concluded that removal of the 3,25 limit will have an overall positive impact on safety.

Basis For No Sicnificant Hazards Consideration ,

According to 10CFR50.92, a proposed change to the license (Technical Specifications) involves no significant hazards consideration if operation of the facility in accordance with the proposed change would not (1) involve a -

significant increase in the probability or consequences of an accident ptev*.ously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

(1) The proposed change does not involve a significant increase in the probability or consequences of a previously evaluated accident. As noted in the Generic Letter and in the proposed BASES for Specification 4.0.2, the limitations imposed by this Specification are based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements (irrespective of the allowed extension of the surveillance interval). The proposed change to specification 4.0.2 should not therefore yield any significant

l. degradation in the reliability (ensured by the performance of i

s surveillanc6 activities) of associated systems or components, including those designed to mitigate the consequences of design basis (previously evaluated) accidents or whose integrity is required to reduce the probability of occurrence of such accidents.

(2) The scope of the proposed change is limited only to the slight change in the maximum allowed extension of surveillance intervals. The proposed change does not affect the surveillance test requirements themselves (i.e., the acceptance criteria, scope, etc.). Nor does the proposed change affect plant design or operation (other than the impact on scheduling surveillance activities). Therefore, the proposed change RFP2:GSL9

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> . (3) The proposed changes do not involve a significant reduction in a margin of safety. As noted in CL 89 14. removal of the 3.25 limit may effect r an enhancement to plant safety since it will allow surveillances to be I delayed (up to 254) if plant conditions are not suitable for performing r

the surveillance when the 3.25 limit is reached.

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2 e co 4 U-601548 LS-89-017 Page 4 of 7 APPLICABILITY ,

SURVEILLANCE ' REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS  !

or other conditions specified for individual Limiting Conditions for Operation unlest otherwise stated in an individual Surveillance Requirement. p f4. 0. 2 Each Surveillance Requirement shall be performed withiri the specified EP%2 time: interval with; M in se/t.

a A maximum allowable extension not to exceed 25% of the surveillance

f. interval, but

b. The combined time interval for any three consecutive surveillance intervals ,

t shall,_nol.sxceed_3J5 Emes the specified surveillance interval. -

4.0.3 Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications. Surveillance requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL CONDITION or oth'er specified applicable condition shall not be made unless the Surveillance Requirement (s) associated r

} with the Limiting applicable Condition surveillance for Operation interval hate been or as otherwise performed within the s.pecified.

4.0.5 Surveillance Requirements for in' service inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

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a. Inservice inspection of ASME Code Class I, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code- -

and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant ,

to 10 CFR 50, Section 50.55a(g)(6)(i).

b.. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel ,

Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

ASME Boiler and Pressure Vessel Required frequencies Coce and applicable Addenda for performing. inservice terminology for inservice inspection and t,e sting inspection and testing activities activities Weekly At least once per 7 days .

' Monthly At least once per 31 days i Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days E Yearly or annually At least once per 366 % .

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Insert for Page 3/4 0 2 4.0.2 -Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

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tg.g9 017 Page 6 of 7 APPLICABILITY BASES 4.0.1 This specification provides,that surveillance ac,tivities, necessary to ensure the Limiting Conditions for Operation are met, will-be performed during the OPERATIONAL CONDITIONS or other conditions for which the'. Limiting Conditions for Operation are applica51e. Provisions for additional surveillance activities, to be performed without regard to the applicable OPERATIONAL CONDITIONS Requirements.

or other conditions, are provided in the individual Surveillance Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.

f 4. 0. 2 The provisions of this specification provide allowable tolerances for "

_,,4 gg  ; performing surveillance activities beyond those specified in the nominc1 surveillance interval. These tolerances are necessary to provide operational

g. flexibility because of scheduling and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this

}surveillanceactivities.aliowable tolerance; instead, it permits the more frequent performance

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The tolerance values, taken either individually or consecutively over three

• test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond /

that obtained'from the nominal specified interval.

j 4.0.3 The provisions of this specification set forth the criteria for deter-mination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation. Under these criteria, equipment, systems, or compo-nents are assumed to be OPERABLE if the associated surveillance activities have been satisfactorily performed within the specified time interval. Nothing in this provision is to be construed as defining equipment, systems or components ..

OPERABLE, when such items are found or known to be inoperable although still meeting the Surveillance Requirements. ,

4.0.4 This specification ensores that surveillance activities associated '

with a Limiting Condition for Operation have been performed within the speci-fied time interval prior to entry into an applicable OPERATIONAL CONDITION or other specified applicability condition. The intent of this provision is to ensure that surveillance activities have been satisfactorily demonstrated on a current basis as required to meet the OPERABILITY requirements of the Limiting Condition for Operation.

Under the terms of this specification, for example, during initial plant startup or following extended plant outage, the applicable surveillance activi-ties must be performed within the stated surveillance interval prior to placing or returning thir system or equipment into OPERABLE status.

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Insert for Page B 3/4 0 2 4.0.2 Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g.,

transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18 month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillanci. interval.

RFP2:CSL9

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