NRC Generic Letter 1989-14
UNITED STATES NUCLEAR REGULATORY
COMMISSION
D. C. 20555 August 21, 1989 TO: ALL LICENSEES
OF OPERATING
PLANTS, APPLICANTS
FOR OPERATING LICENSES, AND HOLDERS OF CONSTRUCTION
PERMITS SUBJECT: LINE-ITEM
IMPROVEMENTS
IN TECHNICAL-SPECIFICATIONS
-REMOVAL OF THE 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS (GENERIC LETTER 89-44)Specification
4.0.2 of the Standard Technical Specifications allows surveil-lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur-veillance interval.A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur-veillance intervals.
Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25-percent allowance to extend surveillance intervals.
The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure.
Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility.
Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.Sincerely, J mes 6. Partlow A sociate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the 3.25 Limit of Extending Surveillance Intervals 2. List of Most Recently Issued NRC Generic Letters A 2 l 5 Enclosure
1 GUIDANCE FOR THE PREPARATION
OF A LICENSE AMENDMENT
REQUEST TO REMOVE THE 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS
BACKGROUND
Specification
4.0.2 of the Standard Technical Specifications permits surveil-lance intervals to be 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 con-ducting a surveillance, for example, under transient conditions or other ongo-ing surveillance or maintenance activities.
Specification
4.0.2 also limits extending surveillances so that the combined time interval for any three con-secutive surveillance intervals shall not exceed 3.25 times the specified sur-veillance interval.
The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25 percent.Commmonwealth Edison Company (CECo) submitted a lead-plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.25 limit for surveil-lances that are performed during a refueling outage and are specified with an 18-month surveillance interval.
After discussions with the staff, CECo amended the proposal to remove the 3.25 limitation for all surveillances.
The amended proposal was approved by the staff on a lead-plant basis. Consistent with NRC policy, this Generic Letter provides guidance for license amendment requests to implement this line-item improvement in TS.DISCUSSION
_ _Experience has shown that the 18-month surveillance interval, with the provi-sion 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 routinely granted requests for one-time exceptions to the 3.25 limit on extending refuel-ing surveillances because the risk to safety is low in contrast to the alter-native of a forced shutdown to perform these surveillances.
Therefore, the 3.25 limitation on extending surveillances has not been a practical limit on the use of the 25-percent allowance for extending surveillances that are performed on a refueling outage basis.The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are perform-ed on a routine basis during plant operation.
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 ser-vice 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 limiting three con-secutive surveillance intervals to the 3.25 limit. Also, there is the adminis-trative 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 staff concluded that removal of the 3.25 limit will have an overall positive impact on safety.An acceptable alternative to the existing requirements of Specification
4.0.2 is the following:
8908210105
-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.Licensees should also propose changes to update the Bases Section of Specifica- tion 4.0.2. Generic Letter 87-09 provided updated Bases for Specification
4.0.2. The following changes to the Bases of Specification
4.0.2, as provided in Generic Letter 87-09, are shown underlined to reflect this change.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 tfofacilitate.
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 f5F surveillances that are performed at each retueling outa ge and are s ec-ified with a 12-l an 18-1month surveillance interval.
it Is not intended that this provision be used repeatedly as a convenience to extend surveil-lance intervals beyond that specified for surveillances that are not per-formed during Tefueling outages. The limitation ot 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.-
--SUMMARY This alternative to the requirements of Specification
4.0.2 will remove an un-necessary restriction on extending surveillance requirements and will result in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements.
The removal of the 3.25 limit will provide -greater flexibility in the use of the provision for extending surveillance in-tervals, reduce the administrative burden associated with its use, and have a positive effect on safety.
I LIST OF RECENTLY ISSUED GENERIC LETTERS Enclosure
2 Generic Date of Letter No Subject Issuance Issued To 89-14 LINE-ITEMS
TECHNICAL
SPECIFI- 08/21/89 ALL LICENSEES
OF CATION IMPROVEMENT
-REMOVAL OPERATING
PLANTS, OF 3.25 LIMIT ON EXTENDING
APPLICANTS
FOR SURVEILLANCE
INTERVALS
OPERATING
LICENSES, (GENERIC LETTER 89-14) AND HOLDERS OF CONSTRUCTION
PERMITS 89-13 GENERIC LETTER 89-13 7/18/89 LICENSEES
TO ALL SERVICE WATER SYSTEMS POWER REACTORS PROBLEMS AFFECTING
BWRS, PWRS, AND SAFETY-RELATED
EQUIPMENT
VENDORS IN ADDITION TO GENERAL CODES APPLICABLE
TO GENERIC LETTERS 89-12 GENERIC LETTER 89-12: 7/6/89 LICENSEES
TO ALL OPERATOR LICENSING
POWER REACTORS EXAMINATIONS
BWRS, PWRS. AND VENDORS IN ADDITION TO GENERAL CODES APPLICABLE
TO GENERIC LETTERS 89-11 GENERIC LETTER 89-11: 6/30/89 ALL BWR PLANTS I RESOLUTION
OF GENERIC ISSUE ALL LISTINGS 101 'BOILING WATER REACTOR APPLICABLE
TO WATER LEVEL REDUNDANCY'
GENERIC LETTERS &VENDORS, ETC.89-10 GENERIC LETTER 89-10: 6/28/89 LICENSEES
TO ALL SAFETY-RELATED
MOTOR-OPERATED
POWER REACTORS, VALVE TESTING AND SURVEILLANCE
BWRS, PWRS, AND VENDORS IN ADDITION TO GENERAL CODES APPLICABLE
TO GENERIC LETTERS 89-09 ASME SECTION III COMPONENT
5/8/89 ALL HOLDERS OF LIGHT REPLACEMENTS
WATER REACTOR OPERATING
LICENSES 89-08 ISSUANCE OF GENERIC LETTER 5/2/89 LICENSEES
TO ALL 89-08: EROSION/CORROSION
-POWER REACTORS, INDUCED PIPE WALL THINNING -BWRS, PWRS, AND 10 CFR 550.54(f)
VENDORS IN ADDITION TO GENERAL CODES APPLICABLE
TO GENERIC LETTERS UNITED STATES FIRST CLASS MAIL NUCLEAR REGULATORY
COMMISSION
POSTAGE SEES PAID WASHINGTON, D.C. 20555 USNRC PERMIT No. 6.6 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300
August 21, 1989-' TO: ALL LICENSEELI
OPERATING
PLANTS, APPLICANTS
EVE OPERATING LICENSES, AND HOLDERS OF CONSTRUCTION
PERMITS SUBJECT: LINE-ITEM
IMPROVEMENTS
IN TECHNICAL
SPECIFICATIONS
-REMOVAL OF THE 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS (GENERIC LETTER 89-14)Specification
4.0.2 of the Standard Technical Specifications allows surveil-lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur-veillance interval.A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur-veillance intervals.
Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25-percent allowance to extend surveillance intervals.
The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure.
Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility.
Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.Sincerely, Original signed by James G. Partlow James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the 3.25 Limit of Extending Surveillance Intervals 2. List of Most Recently Issued NRC Generic Letters Distribution:
See Attached Concurrence:
Te following individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR: TGDunning OTSB:DOEA;
RLEmch, OTSB:DOEA;
EJButcher, C:OTSB:DOEA;
BCalure, TECH EDIT6R; CHBerlinger, C:GCB:DOEA;
CERossi, D:DOEA:NRR;
FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR, JHSniezek, DD:NRR In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director, NRR, ted August , 1989, CRGR waived their review of this Generic Letter.Jose A. Calvo, Chief ,.1<X *See previous concurrence Technical Specifications Branch AD:ADP:NR
ADT JGi'artlow F8i lia Er, Fl tco py'-;08/~-'/89 i IE EN
TO ALL POWER REACTOR LICENSEES
AND APPLICANTS
SUBJECT: LINE-ITEM
IMPROVEMENTS
IN TECHNICAL
SPECIFICATIONS
-REMOVAL OF THE 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS (Generic Letter 89- )Specification
4.0.2 of the Standard Technical Specifications allows surveil-lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur-veillance interval.A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur-veillance intervals.
Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25-percent allowance to extend surveillance intervals.
The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure.
Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility.
Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.Sincerely, James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
As stated Distribution:
See Attached Concurrence:
The following individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR: TGDunning, OTSB:DOEA;
RLEmch, OTSB:DOEA;
EJButcher, C:OTSB:DOEA;
BCalure, TECH EDITOR; CHBerlinger, C:GCB:DOEA;
CERossi, D:DOEA:NRR;
FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR. JHSniezek, DD:NRR In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director, NRR, dated August31, 1989, CRGR waived their review of this Generic Letter.A;Jose A. Calvo, Chief Technical Specifications Branch AD:ADP:NRR
ADT v JGPartlow FMir 7 d 7 q O8/ /89 0 8 ft"9 g ~ S
' 'Generic Letter 89-14 i<. August 21, 1989 Distribution:
TEhurley JHSniezek FJMiraglia JGPartlow SAVarga DMCrutchf ield JWRoe ELdordan FJCongel FGillesple JZwolinski GMHolahan ACThadani HSmith JACalvo CHBerlinger CJHaughney JLieberman BDLiaw CERossi GCLainas JHConran CIGrimes WGKennedy MGMalsch SATreby JERichardson PDR OTSB Members OTSB R/F DOEA R/F~&-~Central Files P_O: AL LAugust 21, 1989 TO: ALL LICENSEES
OF OPERATING
PLANTS, APPLICANTS
FOVOPERATING
LICENSES, AND HOLDERS OF CONSTRUCTION
PERMITS SUBJECT: LINE-ITEM
IMPROVEMENTS
IN TECHNICAL
SPECIFICATIONS
-REMOVAL OF THE 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS (GENERIC LETTER 89-14)Specification
4.0.2 of the Standard Technical Specifications allows surveil-lance intervals to be extended up to 25 percent of the time interval specified.
In addition, this specification limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified sur-veillance interval.A lead-plant proposal was submitted by Commonwealth Edison for the LaSalle Technical Specifications (TS) to modify the 3.25 limitation on extending sur-veillance intervals.
Based on the review of the Commonwealth Edison proposal, the NRC staff concludes that the removal of the 3.25 limit from Specification
4.0.2 results in a greater benefit to safety than limiting the use of the 25-percent allowance to extend surveillance intervals.
The enclosed guidance is provided for the preparation of a license amendment request to implement this line-item improvement in TS.Licensees and applicants are encouraged to propose changes to plant TS that are consistent with the guidance provided in the enclosure.
Conforming amendment requests will be expeditiously reviewed by the NRC Project Manager for the facility.
Proposed amendments that deviate from this guidance will require a longer, more detailed review. Please contact the Project Manager if you have questions on this matter.Sincerely, Original signed by James G. Pafflow James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
1. Guidance for the Preparation of a License Amendment Request to Remove the 3.25 Limit of Extending Surveillance Intervals 2. List of Most Recently Issued NRC Generic Letters Distribution:
See Attached Concurrence:
lihrleT1TiTng individuals concurred in this Generic Letter by their concurrence in the May 10, 1898 memorandum forwarding the Generic Letter to CRGR: TGDunning, OTSB:DOEA;
RLEmch, OTSB:DOEA;
EJButcher, C:OTSB:DOEA;
BCalure, TECH EDITOR; CHBerlinger, C:GCB:DOEA;
CERossi, D:DOEA:NRR;
FJCongel D:DREP:NRR;
LCShao, D:DEST; SATreby, OGC; FJMiraglia, ADT:NRR, JHSniezek, DD:NRR In a memorandum from ELJordan, Chairman, CRGR, to JHSniezek, Deputy Director,?HRR, ted August , 1989, CRGR waived their review of this Generic Letter.\L \Jose A. Calvo, Chief= *See previous concurrence Technical Specifications Branch AD:ADP:NRA.
ADT *JGPartlow F r4 ia 0B/'~-/89 e
1. I August 21, 1989 MEMORANDUM
FOR: All Project Managers FROM: James 6. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation SUBJECT: A LINE-ITEM
TECHNICAL
SPECIFICATION
IMPROVEMENT
-REMOVAL OF 3.25 LIMIT ON EXTENDING
SURVEILLANCE
INTERVALS (GENERIC LETTER 89-14)Enclosed is Generic Letter 89-14 which is being sent to all power reactor licensees and applicants.
It provides guidance for the preparation of a license amendment request to implement a line-item improvement in Technical Specifications (TS) to remove the 3.25 limit on extending surveillance inter-vals. Any request for this change in TS is voluntary.
It is intended that Project Managers will review and process proposed amend-ments conforming to the guidance of the Generic Letter. Generally, it should not be necessary to consult or to obtain review assistance from the Technical Specifications Branch unless the proposed amendment deviates from the Generic Letter guidance.Enclosed is a model Safety Evaluation Report (SER) that was prepared by the Technical Specifications Branch. This model SER should facilitate your prepara-tion of a license amendment to implement the line-item improvement in TS.If you should have any questions on the Generic Letter or model SER, contact Tom Dunning, OTSB, on extension
21189. The Lead Project Manager for this task is Harley Silver on extension
21470. Harley will assist you in the preparation of a NSHC prenotice for a proposed amendment conforming to the Generic Letter and he should be included on concurrence for the license amendment package.Original signed by JJamesS a rtow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosures:
Generic Letter 89-14 Model SER cc wfenclosures:
J. Taylor H. Thompson Division Directors, KRR Associate Directors, NRR Project Directors, NRR DISTRIBUTION
Regional Administrators tieiniTR77Ms J. Conran, CRGR NRC PDR H. Silver OTSB/RF C. Berlinger, DOEA T. Dunning S. Treby, OGC (3.25 memo) *See prior concurrence
- OTSB:DOEA
- OTSB:DOEA
- C:OTSB:DOE
AD:ADP R TGDunning*
RLEmch* JACalvo* JGPartlo 08/14/89 08/14/89 08/14/89 O8A /89 J-00.