HNP-12-098, Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process

Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process

ML12296A419
Person / Time
Site:	Harris
Issue date:	10/22/2012
From:	Hamrick G Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
HNP-12-098
Download: ML12296A419 (18)

Text

George T. Hamrick Vice President Harris Nuclear Plant 5413 Shearon Harris Rd New Hill NC 27562-9300 919-362-2502 October 22, 2012 10 CFR 50.90 Serial: HNP-12-098 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400

Subject:

Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Carolina Power & Light Company is submitting a request for an amendment to the Technical Specifications (TS) for Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

The proposed amendment would modify TS requirements for missed surveillances in Surveillance Requirement (SR) 4.0.3 and also TS SR 4.0.1 to address how a surveillance requirement is met, for consistency with the model safety evaluation.

provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. provides a summary of the regulatory commitment made in this submittal. provides the existing TS Bases pages marked up to show the proposed change (for information only).

HNP requests approval of the proposed License Amendment by April 30, 2013, with the amendment being implemented within 90 days of issuance.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of North Carolina.

Please refer any questions regarding this submittal to Mr. Dave Corlett, Supervisor -

Licensing/Regulatory Programs, at (919) 362-3137.

HNP-12-098 I declare, under penalty of perjury, that the foregoing is true and correct. Executed on [ I o / 9;'1--/ \ ]

• Sincerely, Attachments (5) cc: Mr. J.D. Austin, NRC Sr. Resident Inspector, HNP Ms. A. T. Billoch Colon, NRC Project Manager, HNP Mr. W. L. Cox Ill, Section Chief, N.C. DENR Mr. V. M. McCree, NRC Regional Administrator, Region II Page 2 HNP-12-098 Page 1 of 5 Attachment 1 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process Attachment 1 Description of the Proposed Change, the Requested Confirmation of Applicability, and Plant-Specific Verifications Contents 1.0 Description 2.0 Assessment

2.1 Applicability of Published Safety Evaluation

2.2 Optional Changes and Variations

3.0 Regulatory Analysis 3.1 Significant Hazards Consideration

3.2 Verification and Commitments

4.0 Environmental Consideration

4.1 Incorporation of TSTF-358, Revision 6

4.2 Incorporation of Improved Standard Technical Specification Wording for HNP TS SR 4.0.1

HNP-12-098 Page 2 of 5 Attachment 1 1.0 Description The proposed amendment would modify Technical Specifications (TS) requirements for missed surveillances in Surveillance Requirement (SR) 4.0.3 and also TS SR 4.0.1 to address how a surveillance requirement is met, for consistency with the TSTF-358 model safety evaluation.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-358 Revision 6, "Missed Surveillance Requirements." The availability of this TS improvement was published in the Federal Register on September 28, 2001, as part of the consolidated line item improvement process (CLIIP).

To facilitate implementation of TSTF-358 into the HNP TS, SR 4.0.1 and its associated Bases require revision for consistency with the corresponding NUREG-1431, Rev. 4, "Standard Technical Specifications Westinghouse Plants," Specification 3.0.1, to address how a surveillance is met and to specify the actions required for a missed surveillance.

A TS Bases Control Program, required for implementation of TSTF-358, was previously incorporated into the HNP TS by License Amendment 127, dated June 12, 2008.

2.0 Assessment 2.1 Applicability of Published Safety Evaluation HNP has reviewed the model safety evaluation dated June 14, 2001 and the comment incorporation dated September 28, 2001, as part of the CLIIP.

This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-358.

HNP has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to HNP and justify this amendment for the incorporation of the changes to the HNP TS. 2.2 Optional Changes and Variations HNP is not proposing any variations or deviations from the intent of the TS changes described in the TSTF-358, Revision 6, or the NRC staff's model safety evaluation dated June 14, 2001 and modified by staff review and comments dat ed September 28, 2001. However, to ensure consistent implementation of TSTF-358 with the justification and safety analysis provided, HNP is also revising HNP TS SR 4.0.1 and its associated Bases for consistency with its corresponding improved STS Sections 3.0.1, to address how a surveillance is met and to specify the actions required for a missed surveillance. Minor variations/deviations in the TS terminology used in NUREG-1431 and TSTF-358 are required because the HNP TS are not in the improved TS format and the wording does not directly correspond to the improved STS and TSTF-358 wording in every instance.

For example, the HNP TS do not use the improved STS terms Completion Times, Required Actions or Frequencies, rather they use the corresponding terms specified time intervals, ACTION requirements, and surveillance intervals instead. These and HNP-12-098 Page 3 of 5 Attachment 1 similar terminology variations/deviations from TSTF-358 and STS SR 3.0.1 wording are necessary to ensure that the language used in the License Amendment Request is consistent with the terminology used throughout the HNP TS. However, the minor variations/deviations from the specific wording included in the NUREG CLIIP do not change the intent of the TS, Bases or CLIIP.

The variations/deviations in TS terminology are consistent with the wording used in a similar License Amendment Request submitted by Virginia Electric and Power Company (Dominion) on January 31, 2007 (ML070320178). The NRC approved the License Amendment Request in a letter dated May 3, 2007 (ML070930193

). 3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination HNP has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

HNP has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to HNP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

HNP has also evaluated whether a significant hazards consideration is involved by incorporating the wording of improved STS Surveillance Requirement (SR) 3.0.1, as specified in NUREG-1431, into HNP TS SR 4.0.1. This change has been made to the extent practical to facilitate the incorporation of Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-358, Revision 6, regarding missed surveillance requirements. Based on this evaluation, HNP has determined that no significant hazards consideration exists based on the following: 1. Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No

The proposed change to incorporate the requirements of improved STS SR 3.0.1 into corresponding HNP TS SR 4.0.1, does not affect the design or operation of the plant. The proposed change involves revising the existing HNP TS to be consistent with NUREG-1431, Revision 4, to facilitate the incorporation of TSTF-358 into the TS. The proposed change involves no technical changes to the existing TS as it merely clarifies how SRs are met.

As such, these changes are administrative in nature and do not affect initiators of analyzed events or assumed mitigation of accident or transient events.

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

HNP-12-098 Page 4 of 5 Attachment 1

2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?

Response: No.

The proposed change to incorporate the requirements of improved STS SR 3.0.1 into corresponding HNP TS SR 4.0.1, does not involve a physical alteration to the plant (no new or different type of equipment will be installed) or changes in methods governing normal plant operation. The proposed change revises the existing HNP TS to be consistent with NUREG-1431, Revision 4, to clarify how SRs are met and facilitates the incorporation of TSTF-358 for addressing missed surveillances. As such, the proposed change will not impose any new or different requirements or eliminate any existing requirements. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed Change Involve a Significant Reduction in a Margin of Safety?

Response: No.

The proposed change to incorporate the requirements of improved STS SR 3.0.1 into corresponding HNP TS SR 4.0.1, does not affect plant operation or safety analysis assumptions in any way. The change provides additional clarification on how a surveillance is met and facilitates the incorporation of TSTF-358 for addressing missed surveillances.

The change is administrative in nature and does not affect the operation of safety-related systems, structures, or components. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

3.2 Verification and Commitments

As discussed in the notice of availability published in the Federal Register on September 28, 2001, for this TS improvement, plant-specific verifications were performed as follows:

To facilitate implementation of TSTF-358, HNP is incorporating the wording from the improved STS SR 3.0.1 and SR 3.0.3 and their associated Bases into corresponding HNP TS SR 4.0.1 and SR 4.0.3 respectively, as well as the changes included in TSTF-358.

HNP will establish TS Bases for SR 4.0.3 which state that the use of the delay period established for SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of a missed surveillance.

The modification will also include changes to the Bases for SR 4.0.3 that provide detail 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 HNP-12-098 Page 5 of 5 Attachment 1 HNP 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 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 then be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that a missed surveillance for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the course of action. In addition, the Bases state that all missed surveillance tests will be placed in the licensee's Corrective Action Program. Finally, the HNP has a Bases Control Program TS (6.8.4.n) consistent with Section 5.5 of the improved STS. 4.0 Environmental Consideration 4.1 Incorporation of TSTF-358, Revision 6 HNP has reviewed the environmental evaluation associated with TSTF-358 included in the model safety evaluation dated June 14, 2001 and modified by staff review and comments dated September 28, 2001, as part of the CLIIP.

HNP has concluded that the staff's findings presented in that evaluation are applicable to HNP, and the evaluation is hereby incorporated by reference for this application.

4.2 Incorporation of Improved Standard Technical Specification Wording for HNP TS SR 4.0. HNP has further determined that the revision of HNP TS SR 4.0.1 and its associated Bases to make them consistent with NUREG-1431, Revision 3, will not result in any significant increases in the amounts of any effluents that may be released offsite or any significant increases in individual or cumulative occupational radiation exposure. The proposed change is administrative in nature, and, as such, does not affect the operation of the plant. Therefore, the proposed change is eligible for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change as the proposed administrative change will not result in an undue risk to the health and safety of the public.

HNP-12-098

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process Attachment 2 Technical Specification Page Mark-ups (1 page plus cover)

APPLICABILITY SURVEILLANCE REqUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other co n ditions specified for individual L1mit1ng Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval. 4.0.3 If 1t is discovered that a surveillance was not performed within 1tS specified surveillance interval.

then compliance with the r equirement to declare the LCD not met may be delayed. from the time of d1scovery.

up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified sU I'veillance interval.

whichever is less. This delay period is permitted to allow performance of the surveillance. If the surve ill ance is not performed w1thin the delay period. the LCD must immediately be declared not met. and the applicable ACT I ON requirements must be met. When the surveillance is performed within the delay period a nd the surveillance criteria are not met. the LCD must immediately be declared not met. and the applicable ACTION requirements must be met. Surveillance ReQu1rements do not have to be performed on inoperable equipment. 4.0.4 Entry into an OPERATIONAL MODE or other spe c ified condition shall not be made unless the Surveillance ReQuirement(s) associated with the Limiting Co nditi on for Oper ati on has been performed within the stated surveillance interval or as otherwise specified.

This prov 1 sion shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. 4.0.5 DELETED SHEARON H ARRIS -UN IT 1 3/4 0-2 Amendment No 127 HNP-12-098

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process Attachment 3 Retyped Technical Specification Page (1 page plus cover)

SHEARON HARRIS - UNIT 1 3/4 0-2 Amendment No. APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation, unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, 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 surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits. 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval. 4.0.3 If it is discovered that a surveillance was not performed within its specified surveillance interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 ACTION requirements must be met. When the surveillance is performed within the delay period and the surveillance criteria are not met, the LCO must immediately be declared not met, and the applicable ACTION requirements must be met.

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 has been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Deleted

HNP-12-098

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process Attachment 4 Regulatory Commitment Summary This document contains the following Regulatory Commitment: Commitment Due Date/Event HNP will establish the Technical Specification Bases for SRs 4.0.1 and 4.0.3 as adopted with the applicable license amendment.

To be implemented with the amendment Any other actions discussed in this document should be considered intended or planned actions. They are included for informational purposes but are not considered Regulatory Commitments.

HNP-12-098

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Application for Technical Specification Change Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process Attachment 5 Technical Specification Bases Mark-ups (For Information Only)

(5 pages plus cover)

APPLICABILITY BASES 4.0.1 This specification provides that surveillance activities necessary to ensure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable.

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 an individual specification.

4.0.2 The provisions of this specification establish 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 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 IS 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. Likewise, it is not the intent that the IS-month interval surveillances be performed during power operation unless it is consistent with safe plant operation.

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 surveillance interval.

4.0.3 Specification 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a surveillance has not been completed within the specified surveillance interval.

A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is less, applies from the point in time that it is discovered that the surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified surveillance interval 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 ACTION requirements 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 a surveillance with a surveillance interval based not on time intervals, but upon specified unit conditions or operational situations, is discovered not to have been performed when specified, Specification 4.0.3 allows the full delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the surveillance.

SHEARON HARRIS -UNIT 1 B 3/4 0-2a Amendment No. S4 I APPLICABILITY BASES 4.0.3 (Continued)

Specification 4.0.3 also provides a time limit for completion of surveillances that become applicable as a consequence of MODE changes imposed by ACTION requirements.

Failure to comply with specified surveillance intervals for surveillance requirements is expected to be an infrequent occurrence.

Use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals.

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 time limits of the ACTION requirements for the applicable LCO 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 time limits of the ACTION requirements for the applicable LCO begin immediately upon the failure of the surveillance.

Completion of the surveillance within the delay period allowed by this Specification, or within the completion time of the ACTIONS, restores compliance with Specification 4.0.1. 4.0.4 This specification establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement.

The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility.

This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup. Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage. When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.

SHEARON HARRIS -UNIT 1 B 3/4 0-2b Amendment No. 84 I TECHNICAL SPECIFICATION BASES MARKUP INSERTS

INSERT 1 Specification 4.0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual surveillances. This Specification is to ensure that surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a surveillance within the specified surveillance interval, in accordance with Specification 4.0.2, constitutes a failure to meet an LCO. Surveillances may be performed by means of any series of sequential, overlapping, or total steps provided the enti re surveillance is performed within the specified surveillance interval. Additionally, the definitions related to instrument testing (e.g., CHANNEL CALIBRATION) specify that these tests are performe d by means of any series of sequential, overlapping, or total steps.

Systems and components are assumed to be OPERABLE when the associated surveillances have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the surveillances; or

b. The requirements of the surveillance(s) are known not to be met between required surveillance performances.

Surveillances do not have to be performed when the unit is in an OPERATIONAL MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The surveillances associ ated with a test exception are only applicable when the test exception is used as an allowable exception to the requirement s of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given surveillance. In this case, the unplanned event may be credited as fulfilling the performance of the surveillance. This allowance includes those surveillances whose performance is normally precluded in a given OPERATIONAL MODE or other specified condition.

Surveillances, including surveillances invoked by ACTION requirements, do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. Surveillances have to be met and performed in accordance with Specification 4.0.2, prior to returning equipment to OPERABLE status.

Upon completion of maintenance, appropriate post main tenance testing is required to declare equipment OPERABLE. This includes ensuring applicable surveillances are not failed and their most recent performance is in accordance with Specification 4.0.2. Post maintenance testing may not be possible in the current OPERATIONA L MODE or other specified conditions in the Applicability due to the necessary unit paramete rs not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to an OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed.

An example of this process is Auxiliary Feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures that cannot be obtained until the unit is at HOT SHUTDOWN conditions. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and othe r necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

INSERT 2 When a surveillance with a surveillance interval based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering OPERATIONAL MODE 1 after each fuel lo ading, or in accord ance with 10 CFR 50, Appendix J, as modified by approved exemptions, et c.) is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the surveillance. However, since there is not a time interval specified, the missed surveillance should be performed at the first reasonable opportunity.

Specification 4.0.3 provides a time limit for, and allowances for the performance of, surveillances that become applicable as a consequence of OPERATIONAL MODE changes imposed by ACTION requirements.

INSERT 3 While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified su rveillance interval 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 additi on to unit conditions, pla nning, availability of personnel, and the time required to perform the surveillance. This ri sk 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, 'Assessi ng 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 action thresholds, 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 met hods. 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 quantita tively. 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 licensee's Corrective Action Program.