ML023120250

Tech Spec Pages for Amendment No. 246, Dated November 1, 2002

ML023120250
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/01/2002
From:	NRC/NRR/DLPM/LPD4
To:
References
TAC MB5279
Download: ML023120250 (6)

Text

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the Surveillance Failure to meet a Surveillance, 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 interval shall be failure to meet the LCO except as provided in 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 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified interval, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or up to the limit of the specified 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 hours1 days <br />0.143 weeks <br />0.0329 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(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTION(s) must be entered.

4.0.4 Entry into an OPERATIONAL MODE or other specified applicability 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. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

ARKANSAS - UNIT 2 3/4 0-2 Amendment No. 42,4O3,434,2-3, 246

Administrative Controls 6.5.14 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without pnor NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license or

2. A change to the updated SAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the SAR.

d Proposed changes that do not meet the criteria of 6.5.14b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e) 6.6 DELETED ARKANSAS - UNIT 2 6-12a Amendment No. 447,460, 209, 246

APPLICABILITY BASES (Continued) the trip function from occurring during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.

4.0 1 through 4 0 4 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10CFR 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 conditions of operation will be met."

4 0 1 establishes the requirement that Surveillances must be performed during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual Surveillance Requirements.

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 interval, in accordance with 4.0.2, constitutes a failure to meet an LCO.

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

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

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

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified. The Surveillance Requirements associated with a special test exception (STE) are only applicable when the STE is used as an allowable exception to the requirements 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 MODE or other specified condition.

ARKANSAS - UNIT 2 B 3/4 0-2 Amendment No. 403,434,207,2M, 246

APPLICABILITY BASES (Continued)

Surveillances, including Surveillances invoked by LCO Action Statements do not have to be performed on inoperable equipment because the Action Statements define the remedial measures that apply. Surveillances have to be met and performed in accordance with 4.0.2, prior to returning equipment to OPERABLE status Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with 4.0.2 Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters 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 a MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are.

a. Emergency feedwater (EFW) pump turbine maintenance during refueling that requires testing at steam pressures > 700 psi. However, if other appropriate testing is satisfactorily completed, the EFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

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 surveillance intervals.

ARKANSAS - UNIT 2 B 3/4 0-2a Amendment No. 246 I

BASES (Continued) 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 interval. A delay period of up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or up to the limit of the specified interval, whichever is greater, 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 interval was not met.

This delay period provides an adequate time to complete Surveillances that have been missed This delay period permits the completion of a Surveillance before complying with required actions 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 an interval based not on time intervals, but upon specified unit conditions, operational situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified 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 MODE changes imposed by required actions.

Failure to comply with specified 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. While up to 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> or the limit of the specified 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 addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This 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 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 methods. 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 quantitatively. 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.

ARKANSAS - UNIT 2 B 3/4 0-3 Amendment No. 4-34,449, 246

BASES (Continued)

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 allowed outage times of the required actions 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 allowed outage times of the required actions for the applicable LCO begin immediately upon the failure of the Surveillance.

Satisfactory completion of the Surveillance within the delay period allowed by this Specification, or within the allowed outage time of the actions, restores compliance with Specification 4.0 1.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE status.

4.0.4 establishes the requirement that all applicable surveillances must be met before into an OPERATIONAL MODE or other condition of operation specified in the Applicability entry 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 condition for which these systems and components ensure safe operation of the or 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 be performed within the specified surveillance interval to ensure that the Limiting must 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 provision of Specification 4.0.4 do not apply because this would delay placing the facility in a lower mode of operation.

ARKANSAS - UNIT 2 B 3/4 0-4 Amendment No. 4-34,2=3, 246