ML19354E581

Proposed Tech Specs Deleting 3.25 Max Limit Applied to Three Consecutive Surveillance Intervals

ML19354E581
Person / Time
Site:	Fort Calhoun
Issue date:	01/24/1990
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML19354E539	List: ML19354E538 ML19354E579 ML19354E581
References
NUDOCS 9001310414
Download: ML19354E581 (7)

Text

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9001310414 900124 PDR ADOCK 05000285 P PDC 6

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SURVEILLANCE REQUIREMENTS 4

h h' 3.0.1 Each surveillance requirement shall be performed within the specified time interval with

a. a maximum allowable extension not to exceed 25% of the surveillance interval, and i i

b. the combined time interval for any three consecutive j  :

surveillance intervals shall not exceed 3.25 times the L specified surveillance interval.  !

! 1 3.0.2 The surveillance intervals are defined as follows: .l ;

Notation Title Frequency S Shift At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i W Weekly At least once per 7 days BW Biweekly At least once per 14 days M Monthly At least once per 31 days-  : ,

Q Quarterly At least once per 92 days  ;

SA Semiannual At least once per 184 days A Annua lly At least once per 366 days '

R Refueling At least once per plant operating cycle i P Start up . Prior to Reactor Start up -if not completed in the previous week.

Exception to these intervals are stated in the individual  ;

Specifications.  !

i 3.0.3 The provisions of Specifications 3.0.1 and 3.0.2 are applicable to all codes and standards referenced within the Technical Specifications. The requirements of the Technical Epecifications shall have precedence over the requirements of the codes and .

standards referenced within the Technical Specifications. I 3.0.4 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specifications 3.0.1 and 3.0.2, shall constitute noncompliance with the OPERABILITY requirements for the corresponding Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is  ;

identified that a Surveillance Requirement has not been performed. I The ACTION requirements may be delayed for.up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. '

Surveillance Requirements do not have to be performed on inoperable-equipment.  !

3-0a Amendment No.122 '

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.0 SURVEILLANCE REQUIREMENTS 4 b BASIS '

Specifications 3.0.1 through 3.0.4 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Reculations,10CFR50.36(c)(3): ,

"Surve111ar.ce requirements are requirements relating to test, i calibration, or inspection to ensure that the necessary quality  !

of systems and components it maintained, that facility operation [

will be within safety limits, and that the limiting condition of l ,

operation will be met."  ;

I Specification 3.0.1 estab~lished the' con'ditions under which the specifieo time interval for Surveillance Requirements may be extended. Item a. l 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. Item b. limits the use of the provisions of item a. to ,

ensure that it is not used repeatedly to extend the surveillance  :

interval beyond that specified. The limits of Specification 3.0.1 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. These provisions are sufficient to ensure that the reliability demonstrated through actual surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

, The provisions of Specification 3.0.2 define the surveill'ance intervals for use in the Technical Specifications. This clarification is .

provided to ensure consistency in surveillance intervals thrcughout l the Technical Specifications. A few surveillance requirements-have

, unccmmon intervals, for example, Table 3-9 requires sampling of fish l once per season. In such a case the surveillance interval shall be '

performed as defined by the individual specifications.

• Specification 3.0.3 extends the testing interval required by codes  ;

and standards referenced by the Technical Specifications. This (

clarification is provided to remove any ambiguities relative to the i i frequencies for performing the required inservice inspection and: i testing activities. Under the terms of this specification, the more restrictive requirements of the Technical Specifications take ,

precedence over the codes and stendards referenced therein.

l Specification 3.0.4 establishes the failure to perform a Survei~11ance-l Requirement within the allowed surveillance interval, as defined by

! the provisions of Specifications 3.0.1 ano 3.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for the corresponding Limiting Condition for Operation. Under the provisions  ;

l 3-Ob Amendment No. 122 L

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3.0 SURVEILLANCE RE0VIREMENTS 3.0.1. Each surveillance requirement shall be performed within the specified '

surveillance interval with a maximum allowable extension not to exceed 25 percent of the surveillance interval.

3.0.2 The surveillance intervals are defined as follows:

Notation Title Freauency S Shift At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W Weekly At least once per 7 days l BW Biweekly At least once per 14 days M Monthly At least once per 31 days Q Quarterly At least once per 92 days SA Semiannual At least once per 184 days A Annually At least once per 366 days R Refueling At least once per plant operating cycle P Startup Prior to Reactor Startup, if not completed in the previous week.

Exception to these intervals are stated in the individual Specifications.

3.0.3 The provisions of Specifications 3.0.1 and 3.0.2 are applicable to all codes and standards referenced within the Technical Specifications.

The requirements of the Technical Specifications shall have precedence over the requirements of the codes and standards referenced within the Technical Specifications.

3.0.4 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specifications 3.0.1 and 3.0.2, shall -

constitute noncompliance with the OPERABILITY requirements for the corresponding Limiting Condition for Operation. The time limits of the l ACTION requirements are applicable at the time it is identified that a l

Surveillance Requirement has not been performed. The ACTION' requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage' time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Surveillance Requirements do not have to be performed on inoperable equipment.

1 3-0a Amendment No. JEJ

4 3.0 SURVEILLANCE RE0VIREMENTS BASIS Specifications 3.0.1 through 3.0.4 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal ,

Requirements, 10 CFR 50.36(c)(3):

" Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting condition of operation will be met."

Specification 3.0.1 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 surveillance that are not performed during refueling outages. The limitation of Specification 3.0.1 is based on engineering judgment 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 surveillance interval.

The provisions of Specification 3.0.2 define the surveillance intervals for use in the Technical Specifications. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications. A few surveillance' requirements have uncommon intervals, for example, Table 3-9 requires sampling of fish once per season. In such-a case the surveillance interval shall be performed as defined by the individual specifications.

Specification 3.0.3 extends the testing interval required by codes and standards referenced by the Technical' Specifications. This ,

clarification is provided to remove any ambiguities relative to the frequencies'for performing the required inservice inspection and testing activities. Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the codes and standards referenced therein.

Specification 3.0.4 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, as defined by the provisions of Specifications 3.0.1 and 3.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for the corresponding Limiting Condition for Operation. Under the provisions 3-Ob Amendment No. JJJ

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DESCRIPTION, JUSTIFICATION AND NO SIGNIFICANT HAZARDS CONSIDERATION Description of amendment request:

The proposed amendment requests deletion of the 3.25 surveillance limit from the Technical Specification 3.0.1 as recommended in the NRC Generic letter 89-14, August 21, 1989. Presently, Specification 3.0.1 allows 1.25 and 3.25 extension on all surveillance test performances. The 3.25 factor limits extending surveillances so that the combined time interval for any three surveillances will not exceed 3,25 times the specified interval. The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent. OPPD accepts the NRC staff considerations and conclusion that removal of the 3.25 factor will have an overall positive impact on safety when applied to fort Calhoun Station.

Basis for No Significant Hazards Consideration:

The proposed change does not involve significant hazards consideration because the operation of fort Calhoun Station in accordance with this amendment would not:

1. involve a significant increase in the probability or consequence of an accident previously evaluated. The 25 percent extension has been evaluated as a reasonable time limit to facilitate the scheduling of surveillance activities and allow surveillances to be postponed when plant conditions are not suitable for conducting a surveillance. The 25 percent is maintained by the 1.25 limit and will not significantly increase the probability or consequences of an accident.

2. create the possibility of a new or different kind of accident from any previously analyzed. The proposed change does not alter the Updated Safety Analysis Report in which the accidents-were previously analyzed and will not create the possibility of a new or different kind of accidents.

3. involve a significant reduction in a margin of safety. The surveillance intervals in determining operability of the plant equipment / systems are not changed and deletion of 3.25 limit will not reduce the margin of safety.

Therefore, based on the above considerations, Omaha Public Power District has determined that the proposed change does not involve significant hazards, em : m -, a