ML20086M497

Proposed Tech Specs 4.0.2 Re Surveillance Requirements

ML20086M497
Person / Time
Site:	Farley
Issue date:	12/11/1991
From:	ALABAMA POWER CO.
To:
Shared Package
ML20086M476	List: ML20086M473 ML20086M497
References
NUDOCS 9112170492
Download: ML20086M497 (7)

Text

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APPLICABILITY SURVEllLANCE RE0VIRIMENTS

1. At least M0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHU100WN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHU1DOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This specification is not applicable in MODES 5 or 6.

4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL H0 DES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillanco Requirement.

4.0.2 Each Surve.illance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the :,urveillance interval.

4.0.3 Failure to perform a Surveillance Requirement

• within the specified time interval shall constitute a failure to meet the OPERABillif requirements for a Litatting Condition for Operation. Exceptions to these requirements are stated in the individual specifications. Surveillance Requirementu do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made.unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.

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

a. Inservice inspection of ASME Code Class 1, 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 10CFR50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10CFR50, Section 50.55a(g){6)(1).

b. Surveillance intervals specified in Section XI of the ASMZ 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:

• Upon determination that the surveillance had beer inadvertently omitted, the Surveillance Requirement shall be successfully performed within the Limiting Condition of Operation (LCO) period which would begin upon discovery.

FARLEY-UNIT 1 3/4 0-2 AMENDMENT NO.

9112170492 R 911211 -

ADOCK 05000343 PDR j

1

• APPLICABILITY BASES mean that nr one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE, or likewise satisfy Specification 3.0.5 (i.e.,

be capable of performing their design functions and hue an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6 Specification 3.0.5 is not applicable, and inus the individual ACTION statements for each applicable limiting Condition for Operation in these MODES must be adhered to.

4.0.1 This spuffication provides that surveillance activities necessory to insure the Limiting Conditions for Operation are met and will be performad during the OPERA 110NAL N0 DES or other conditions for which the limiting Conditions for Operation are applicable. Provisions for additional surveillant.e activities to be performed without regard to the applicable OPERATIONAL H0 DES or other conditions are provided in the individual Surveillance Requirements. Surveillance Requirements fer Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individcal specification.

4.0.2 This specification establishes the limit for which the specified time interval for Survs111ance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitata surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the survr ilance; e.g., transient conditions or other ongoing surveillance or maintenance activities. The allowable tolerance 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; instead, this provision should be used to realize a benefit to safety. The limitation of Specification 4.0.2 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 signifi-cantly degraded beyond that obtained from the specified surveillance interval.

4.0.3 The provisions of this specification set forth the criteria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation. Under this criteria, equipment, systems or components are assumed to be OPERABLE if the associated surveillance activ'. ties have been satisfactorily performed within the specified time interva!. Nothing in this provision is to be construed as defining equipment, systems or components OPERABLE, when such items are known to be inoperable although still meeting the Surveillance Requirements.

FARLEY-UNIT 1 B 3/4 0-3 AMENDMENT NO.

APPLICABILITY

, i SURVEILLANCE 1E0VIREMENTS

1. At least 110T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least il0T SH9TDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and  !

3. At least COLD SHUTOOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.  !

This specification is not applicable in MODES 5 or 6. I 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Cond" tons for '

Operation unless otherwise stated in an individual Surveillance

- Requirement.

4.0.2. Each-Surveillance Requirement shall be performed within the l specified time interval with a maximum allowable extension not to exceed l 25% of the suraillance interval.

4.0.3 Failure to perform a Surveillance Requirement

• within the specified  :'

time interval shall con.titute a failure to meet the OPERABILITY requirements for a. Limiting Condit'on for Operation. Exceptions to these requirements are stated in the individual specifications. Surveillanu ,

Requirements do not have to be performed on inoperable equipment.  :

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have-been performed within the stated surveillance. interval or as otherwise specified. ,

4.0.5 Survaillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2 ar.d 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

'10CFR50, Section 50.55a(g).-except_where: specific written relief has been granted by the Commission pursuant to=10CFR50, Section 1 50.55a(g)(6)(i).

.b. Surveillance intervels 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 A3ME Boiler and

. Pressure. Vessel Code and applicable Addenda shall be applicable as follows in these_ Technical-Spectfications:

i

• Upon. determination that the surveillance had been inadvertently omitted, the Surveillance Requirement shall be successfully performed within the Limiting _ Condition of Operation (LCO) period which would _begin upon. '

- ' discovery .

. FARLEY-UNIT 2 3/4 0-2 AMENDMENT NO.

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kkf11CABILU1 BASES ,

mean that for one division the emergency power souso must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE, or likewise sattsfy Specification 3.0.5 (i.e.,

be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6 Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

4.0.1 This specification providss that turveillance activities necessary to insure the limiting Conditions for Operation are met and will be performed during the OPERATIONAL H0 dis or ether conditions for which the Limiting Conditions for Operation are applic:ble. Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements. Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to c individual specification.

4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of th. 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 c or other onooing surveilitnce or maintenance activities. The allowable tolerance 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; instead, this provision should be used to realize a benefit to safety. The limitation of Specification 4.0.2 is based on engineering. Judgment and the recognition that the most probable result of any particular survelliance being performed is the verification of conformance m th the Surveillance Requirements. This provision is sufficient to ensure tnat the reliability ensured through surveillance activities is not signifi-cantly degraded beyond that-c.btained from the specified surveillance interval.

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-4.0.3 The provisions of this specification set forth the criteria for determination of compliance 11th the OPERABillTY require:nents of the Limiting Conditions for Operation. U) der this criteria, equipment, systems or components are assumed to be OPERABLE if the associated surveillance l activities have been satisfa:torily performed within the specified time i r.t c rn1. Nothing in this p ovision is to be construed as defining equipment, systems or components OPERABil, when such items are known to be inoperable althcugh still meeting the Su veillance Requirements.

l FARLEY-UNIT 2 B 3/4 0-3 AMENDMENT N0.

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Attachment 2 ,

Significant Hazaids Evaluation '

Pursuant to 10 CFR 50.92 s

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Significant Hazards Evaluation Pursuant to 10 CFR 50.92 for the Proposed Change to Technical Specification 4.0.2 EroDosed CD3 ERR Eliminate the limit of 3.25 times i.he specified surveillance interval for any three consecutivs surveillances as required by Technical Specification 4.0.2. Also, clarify the Bases for Specification 4,0.2 to reflect the increased flexibility for scheduling surveillances.

Background

On August 21, 1989 the NRC issued Generic Letter 89-14, "Line-Item lmpruvv-ments in Technical Specifications - Removal of the 3.25 Limit on Extending Surveillance Intervala." In this letter the NRC encouraged licensees to '

modify their technical specifications to eliminate the limit of 3.25 times the specified surveillance interval for any three consecutive surveillances as currently required by Specification 4.0.2. The NRC states that the requirement which allcws exceedance of any surveillance interval by 25 percent of the specif41d interval is sufficient to accommodate normal operating variations.

Analysis Alabama Power Company has reviewed the requirements of 10 CFR 50.92 as they relate to the subject technical specification change and considers this change not to involve a significant hazards consiueration. In support of this conclusion, the following analysis is provided: -

.l. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The surveillance intervals will continue to be constrained by the 25 percent limit. For surveillance' required during refueling shutdown, the risk associated with exceeding the 3.25 limit is nutweighed by'the risk associated with a fcrced shutdown to perforn the surveillance. In addition, deletion of the 3,25 limit actually realizes a safety benefit by permitting-surveillance intervals to be extended such that performance of "at power" surNeillance may be accomplished while the plant is shut down, thus minimizing the risk of an unnecessary transient. Existing equipment surveillance requirements are not affected by this license amendment and the extension of surveillance intervals will continue to be limited by the allowable 25 percent extension limit discussed above. The equipment on which the surveillances are being performed will continue to be proven operable and will continue to be available to respond to and mitigate any previously evaluated transients or accidents. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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• r Significant Hazards Evaluation Pursuant to 10 CFR 50.92 Page 2

2. The proposed change will not create the possibility of a new or dif ferent kind of accident from any previously evaluated. The proposed change would not result in any physical alteration to any plant system, nor would there be a change in the method in which any safety related system performed its function. The change would not result in any equipment being operated in a manner different than that in which it was designed to be operated.

3. The proposed change does not involve a signifi: ant reduction in a margin of safety. Deletion of the 3.25 limit will not significantly affect equipment reliability, rather it will reduce the potential for interrupting normal plant operation due to surveillance scheduling. Survel'. lance intervals will continue to be constrained by the 25 percent limit which is sufficient to ensure reliability of surveilled equipment. The added flexibility in scheduling surveillances afforded by deletion of the 3.25 limit should have a positive safety benefit by allowing surveillances to be performed under appropriate plant conditions.

[onclusion Based on the analysis herewith Alabama Power Company has determined that the technical specifications' changes will not increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or invcive a significant reduction in a margin of safety. Alabama Power Company therefore concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.

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