ML20236N439
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September 29, 1997
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MEMORANDUM TO: Jack E. Rosenthal, Chief Reactor Analysis Branch Safety Programs Division, AEOD FROM: William D. Beckner, Chief 06ginal sgnd b Technical Specifications Branch Associate Director for Projects, NRR
SUBJECT:
DEPORTABILITY OF MISSED TECHNICAL SPECIFICATION SURVEILLANCE UNDER 10 CFR 50.73 The Bases for the 24-hour missed surveillance provision in many facilities' technical specifications states that licensees should report missed surveillance under 10 CFR 50.73.
They also state that the missed surveillance should be reported regardless of whether the surveillance is completed within the allowed delay period. The Bases for the corresponding provision, SR 3.0.3, in the improved standard technical specifications (STS), NUREG 1430 through 1434, intentionally does not address deportability. In general, the STS do not contain requirements that are redundant to regulations, such as 10 CFR 50.73. Omission of the deportability language from the Bases for STS SR 3.0.3 does not relieve licensees from the requirement to report a failure to perform a surveillance within the specified interval.
The specified interval includes the 25 percent extension of STS SR 3.0.2, when this extension applies. STS SR 3.0.3 does not permit licensees to miss surveillance, but specifies appropriate remedial actions in the event a surveillance is missed. _
Upon discovery that the specified surveillance interval has expired, STS SR 3.0.3 allows licensees the opportunity to avoid taking required actions that could result in a uriit shutdown. Since the performance of the surveillance is most likely to be successful, avoiding a shutdown transient for a short time is prudent from a safety standpoint.
However, use of the delay period of STS SR 3.0.3 to perform a surveillance may indicate a programmatic breakdown. Our opinion is that licensees should report pursuant to 10 CFR 50.73(a)(2)(i)(B) occurrences of expired surveillance intervals. Note that STS SR 3.0.3 is also used to allow time to perform surveillance that become applicable during changes in operational modes to comply with TS action requirements. This application of STS SR 3.0.3 is not reportable because it is an allowed exception to the requirement to meet all surveillance prior to entering an operational mode or other specified condition in which the associated limiting condition for operation is applicable.
cc: R. Zimmerman J. Roe L Chandler, OGC E. Adensam B. Boger W. Jones, AEOD J. Ueberman, OE DISTRIBUTION:
FILE CENTER TSB R/F WD8eckner TSB Staff CCHarbuck DSkeen DOCUMENT HAME: G ACCH \TS897157.WPD OFFICE TSB:ADPR:NRR ,, C:TS8:ADPR:NRR ,
l NAME CCHarbuck kk WD8eckner M DATE' 09/f)/97 4 / 1 0/97 OFFICIAL RECORD COPY 9807150127 980624 PDR FOIA -
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\ *....+ ) September 29, 1997 MEMORANDUM TO: Jack E. Rosenthal, Chief Reactor Analysis Branch Safety Programs Division, AEOD FROM: William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects, NRR
SUBJECT:
DEPORTABILITY OF MISSED TECHNICAL SPECIFICATION SURVElLLANCES UNDER 10 CFR 50.73 The Bases for the 24-hour missed surveillance provision in many facilities' technical specifications states that licensees should report missed surveillance under 10 CFR 50.73.
They also state that the missed surveillance should be reported regardless of whether the surveillance is completed within the allowed delay period. The Bases for the corresponding provision, SR 3.0.3, in the improved standard technical specifications (STS), NUREG 1430 through 1434, intentionally does not address deportability, in general, the STS do not contain requirements that are redundant to regulations, such as 10 CFR 50.73. Omission of the deportability language from the Bases for STS SR 3.0.3 does not relieve licensees from the requirement to report a failure to perform a surveillance within the specified interval.
.The specified intervalincludes the 25 percent extension of STS SR 3.0.2, when this extension applies. STS SR 3.0.3 does not permit licensees to miss surveillance, but specifies appropriate remedial actions in the event a surveillance is missed.
Upon discovery that the specified surveillance interval has expired, STS SR 3.0.3 allows licensees the opportunity to avoid taking required actions that could result in a unit shutdown. Since the performance of the surveillance is most likely to be successful, avoiding a shutdown transient for a short time is prudent from a safety standpoint.
However, use of the delay period of STS SR 3.0.3 to perform a surveillance may indicate a programmatic breakdown. Our opinion is that licensees should report pursuant to 10 CFR '
50.73(a)(2)(i)(B) occurrences of expired surveillance intervals. Note that STS SR 3.0.3 is also used to allow time to perform surveillance that become applicable during changes in operational modes to comply with TS action requirements. This application of STS SR 3.0.3 is not reportable because it is an allowed exception to the requirement to meet all i surveillance prior to entering an operational mode or other specified condition in which the j associated limitmg condition for operation is applicable.
cc: R. Zimmerman B. Boger E. Adensam J. Roe l
W. Jones, AEOD t
J. Lieberman, OE L Chandler, OGC
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