NRC Generic Letter 1987-09
-.4 -a 0UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555June 4, 1987TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTSGentlemen:
SUBJECT: SECTIONS 3.0 AND 4.0 OF THE STANDARD TECHNICAL SPECIFICATIONS (STS)ON THE APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION ANDSURVEILLANCE REQUIREMENTS (Generic Letter 87-09)As a part of recent initiatives to improve Technical Specifications (TS), theNRC, in cooperation with the Atomic Industrial Forum (AIF), has developed aprogram for TS improvements. One of the elements of this program is theimplementation of short-term improvements to resolve immediate concerns thathave been identified in investigations of TS problems by both NRC and AIF.'The guidance provided in this generic letter addresses three specific problemsthat have been encountered with the general requirements on the applicabilityof Limiting Conditions for Operation (LCO) and Surveillance Requirements inSections 3.0 and 4.0 of the STS.There are five enclosures to this Generic Letter. Enclosure 1 applies toboth PWR and BWR STS and provides a complete discussion of the three problemsand the staff's position on acceptable modifications of the TS to resolvethem. These modifications should result in improved TS for all plants and areconsistent with the recommendations of NUREG-1024, Technical Specifications --Enhancing the Safety Impact' and the Commission Pojicy Statement on TechnicalSpecification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 ofthe PWR and BWR STS, respectively, which incorporate the modifications beingmade by this Generic Letter. Enclosures 3 and 5: (a) provide the staff'supdate of the bases for the PWR and BWR STS, respectively; (b) reflect themodifications of Sections 3.0 and 4.0 of the STS; and (c) include improvedbases for the unchanged requirements in these sections.The staff concludes that these modifications will result in improved TS forall plants. Licensees and applicants are encouraged to propose changes totheir TS that are consistent with the guidance provided in the enclosures;however, these changes are voluntary for all licensees and current OLapplicants.The staff would like to point out three important points connected with thepresent TS effort. First, it is aware that the TS can be clarified,simplified, and streamlined both as a whole and with respect to thespecifications that are the subject of this Generic Letter. Nonetheless, inkeeping with its short-term and purposefully narrow focus, it decided to keepthese proposed modifications: (a) focused on the three problems; (b) relativelysimple; and (c) consistent with the phrasing of existing TS. Second, afterthe resolution of these and other identified TS problems, the staff willnotify licensees and applicants of its conclusions and resulting proposals foradditional short-term TS improvements. Finally, the staff is not proposing toformally amend the STS at this time. Instead the changes will be factored Intothe development of the new STS anticipated as a part of the implementation ofthe Commission's Policy Statement on Technical Specification Improvements.L___ ____- __ __8706090039__
j o -.2The following is a summary of the three problems covered by the enclosures.The first problem involves unnecessary restrictions on mode changes bySpecification 3.0.4 and inconsistent application of exceptions to it. Thepractical solution is to change this specification to define the conditionsunder which its requirements apply. With respect to unnecessary mode changes,Specification 3.0.4 unduly restricts facility operation when conformance withAction Requirements provides an acceptable level of safety for continuedoperation. For an LCO that has Action Requirements permitting continuedoperation for an unlimited period of time, entry into an operation mode orother specified condition of operation should be permitted in accordance withthe Action Requirements. The solution also resolves the problem ofinconsistent application of exceptions to Specification 3.0.4: (a) which'delays startup under conditions in which conformance to the ActionRequirements establishes an acceptable level of safety for unlimited continuedoperation of the facility; and (b) which delays a return to power operationwhen the facility is required to be in a lower mode of operation as aconsequence of other Action Requirements.The second problem involves unnecessary shutdowns caused by Specification4.0.3 when surveillance intervals are inadvertently exceeded. The solution isto clarify the applicability of the Action Requirements, to specify a specificacceptable time limit for completing a missed surveillance in certaincircumstances, and to clarify when a missed surveillance constitutes aviolation of the Operability Requirements of an LCO. It is overlyconservative to assume that systems or components -re inoperable when asurveillance has not been performed because the vast majority of surveillancesdo in fact demonstrate that systems or components are operable. When asurveillance is missed, it is primarily a question of operability that has notbeen verified by the performance of a Surveillance Requirement. Because theallowable outage time limits of some Action Requirements do not provide anappropriate time for performing a missed surveillance before ShutdownRequirements apply, the TS should include a time limit that allows a delay ofrequired actions to permit the performance of the missed surveillance based onconsideration of plant conditions, adequate planning, availability ofpersonnel, the time required to perform the surveillance, and, of course, thesafety significance of the delay in completing the surveillance. The staffhas concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time limit for completing amissed surveillance when the allowable outage times of the Action Requirementsare less than this limit, or when time is needed to obtain a temporary waiver ofthe Surveillance Requirement.The third problem involves two possible conflicts between Specifications 4.0.3and 4.0.4. The first conflict arises because Specification 4.0.4 prohibitsentry into an operational mode or other specified condition when SurveillanceRequirements have not been performed within the specified surveillanceinterval. A conflict with this requirement exists when a mode change isrequired as a consequence of Action Requirements and when the SurveillanceRequirements that become applicable have not been performed within the specifiedsurveillance interval. Specification 4.0.4 should not be used to preventpassage through or to operational modes as required to comply with ActionRequirements because to do so: (a) would increase the potential for a plant
< -3-upset; and (b) would challenge safety systems. Also, certain surveillancesshould be allowed to be performed during a shutdown to comply with ActionRequirements. Along with the modification of Specification 4.0.3 to permit adelay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of Action Requirements,Specification 4.0.4 has been clarified to allow passage through or tooperational modes as required to comply with Action Requirements.A second conflict could arise because, when Surveillance Requirements can onlybe completed after entry into a mode or specified condition for which theSurveillance Requirements apply, an exception to the requirements ofSpecification 4.0.4 is allowed. However, upon entry into this mode orcondition, the requirements of Specification 4.0.3 may not be met because theSurveillance Requirements may not have been performed within the allowedsurveillance interval. Therefore, to avoid any conflict between Specifications4.0.3 and 4.0.4, the staff wants to make clear: (a) that it is not the intentof Specification 4.0.3 that the Action Requirements preclude the performance ofsurveillances allowed under any exception to Specification 4.0.4; and (b) thatthe delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability ofAction Requirements now provides an appropriate time limit for the completionof those Surveillance Requirements that become applicable as a consequence ofallowance of any exception to Specification 4.0.4.If you have any questions on this matter, please contact your project manager.
Sincerely,Original signea oyFrank J. XtregliaFrank J. Miraglia,for ProjectsOffice of Nuclear IAssociate DirectorReactor Regulation
Enclosures:
As stated(SECTIONS 3.0 AND 4.0)*See previous concurrenceTSB:DOEA:NRR*TGDunning05/ /87TSB:DOEA:NRR*DCFischer05/ /87F gli a0 4 /87C:TSB:DOEA:NRR*EJButcher05/ /87D:DOEA:NRR*CERossi05/ /87AD:ADT:NRR*RWStarostecki05/ /87 Enclosure 1 to Generic Letter 87-09ALTERNATIVES TO THE STS REQUIREMENTS TO RESOLVETHREE SPECIFIC PROBLEMS WITH LIMITING CONDITIONSFOR OPERATION AND SURVEILLANCE REQUIREMENTSI NTRODUCTIONGeneric Letter 87-09 discusses three problems regarding the general requirementsof Sections 3.0 and 4.0 of the STS on the applicability of Limiting Conditionsfor Operation (LCO) and Surveillance Requirements. The guidance provided inthis enclosure addresses alternatives to the Standard Technical Specifications(STS) to resolve these problems.Problem #1 -- UNNECESSARY RESTRICTIONS ON MODE CHANGES (Specification 4.0.3)°
BACKGROUND
The definition of an LCO is given in 10 CFR 50.36 as the lowest functionalcapability or performance level of equipment required for safe operation ofthe facility. Further, it is stated that when an LCO of a nuclear reactor isnot met, the licensee shall shut down the reactor or follow any remedialaction permitted by the TS until the condition can be met.Consistent with NRC's regulatory requirements for an LCO, the TS include twobasic types of Action Requirements that are applicable when the LCO is notmet. The first specifies the remedial actions that permit continued operationof the facility not restricted by the time limits of Action Requirements. Inthis case, conformance to the Action Requirements 'rovides an acceptable levelof safety for continued operation of the facility, and operation may proceedindefinitely as Iong as the remedial Action Requirements are met. The secondtype of Action Requirement specifies a time limit in which the LCO must bemet. This time limit is the time allowed to restore an inoperable system orcomponent to operable status or to restore parameters within specified limits.If these actions are not completed within the allowable outage time limits,action must be taken to shut down the facility by placing it in a mode orcondition of operation in which the LCO does not apply.Specification 3.0.4 of the STS states that entry into an operational model orother specified condition shall not be made unless the LCO is met withoutreliance on the provisions of the Action Requirements. Its intent is to ensurethat a higher mode of operation is not entered when equipment is inoperable orwhen parameters exceed their specified limits. This precludes a plant startupwhen actions are being taken to satisfy an LCO, which -- if not completed withinthe time limits of the Action Requirements -- would result in a plant shutdownto comply with the Action Requirements.*The BWR STS use the term "operational condition" instead of the term"operational mode" that is used in PWR STS. As used here, operational mode"means "operational condition" for BWR Specification 3.0.4 also precludes entering a mode or specified condition if anLCO is not met, even if the Action Requirements would permit continued operationof the facility for an unlimited period of time. Generally, the individualspecifications that have Action Requirements which allow continued operationnote that Specification 3.0.4 does not apply. However, exceptions toSpecification 3.0.4 have not been consistently applied and their bases are notwell documented. For example, approximately two-thirds of the actions whichpermit continued operation in the Westinghouse STS are exempt from Specification3.0.4. Although the staff encourages the maintenance of all plant systems andcomponents in an operable condition as a good practice, the TS generally havenot precluded entering a mode with inoperable equipment when the ActionRequirements include remedial measures that provide an acceptable level ofsafety for continued operation.o STATEMENT OF THE PROBLEMInconsistent application of exceptions to Specification 3.0.4 impacts theoperation of the facility in two ways. First, it delays startup underconditions in which conformance to the Action Requirements establishes anacceptable level of safety for unlimited continued operation of the facility.Second, it delays a return to power operation when the facility is required tobe in a lower mode of operation as a consequence of other Action Requirements.In this case, the LCO must be met without reliance on the Action Requirementsbefore returning the facility to that operational mode or other specifiedcondition for which unlimited continued operation was previously permitted inaccordance with the Action Requirements.o STAFF POSITIONSpecification 3.0.4 unduly restricts facility operation when conformance to theAction Requirements provides an acceptable level of safety for continuedoperation. For an LCO that has Action Requirements permitting continuedoperation for an unlimited period of time, entry into an operational mode orother specified condition of operation should be permitted in accordance withthose Action Requirements. This is consistent with NRC's regulatoryrequirements for an LCO. The restriction on a change in operational modes orother specified conditions should apply only where the Action Requirementsestablish a specified time interval in which the LCO must be met or a shutdownof the facility would be required. However, nothing in this staff positionshould be interpreted as endorsing or encouraging a plant startup withinoperable equipment. The staff believes that good practice should dictate thatthe plant startup should normally be initiated only when all required equipmentis operable and that startup with inoperable equipment must be the exceptionrather than the rule.o CHANGE TO SPECIFICATION 3.0.4The practical solution to this problem is not the modification of TS to notethat Specification 3.0.4 does not apply, but rather a change to Specification3.0.4 to define the conditions under which its requirements do apply.Therefore, Specification 3.0.4 will be revised to state:-2 -
Entry into an OPERATIONAL MODE or other specified condition shall not beuade when the conditions for the Limiting Conditions for Operation are notmet and the associated ACTION requires a shutdown if they are not metwithin a specified time interval. Entry into an OPERATIONAL MODE orspecified condition may be made in accordance with ACTION requirementswhen conformance to them permits continued operation of the facility foran unlimited period of time."° CHANGES TO INDIVIDUAL SPECIFICATIONS EXEMPT FROM SPECIFICATION 3.0.4As a consequence of the modification described above to Specification 3.0.4,individual specifications with Action Requirements permitting continued operationno longer need to indicate that Specification 3.0.4 does not apply. They shouldbe revised to delete the noted exception to avoid confusion about theapplicability of Specification 3.0.4. However, exceptions to Specification3.0.4 should not be deleted for individual specifications if a mode change wouldbe precluded by Specification 3.0.4 as revised. For example, some specificationswould not satisfy the provisions under which mode changes are permitted by therevision to Specification 3.0.4 and, therefore, the exception to Specification3.0.4 need not be deleted. It is not the staff's intent that the revision ofSpecification 3.0.4 should result in more restrictive requirements forindividual specifications.Problem #2 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSINGOF SURVEILLANCE INTERVALS (Specification 4.0.3)e
BACKGROUND
Surveillance Requirements are defined in 10 CFR 50.36 as those requirementsrelating to test, calibration, or inspection to ensure that the necessaryquality of systems and components is maintained, that the facility will bewithin the safety limits, and that the LCO will be met.Consistent with the NRC's regulatory framework for Surveillance Requirements,Specification 4.0.3 states that the failure to perform a surveillance within thespecified time interval shall constitute a failure to meet the LCO's OperabilityRequirements. Therefore, if a Surveillance Requirement is not met as a resultof the failure to schedule the performance of the surveillance, the LCO wouldnot be met. Consequently, the LCO's Action Requirements must be met as when asurveillance verifies that a system or component is inoperable.Generally, the Action Requirements include a specified time interval (i.e.,allowable outage time limit) that permits corrective action to be taken tosatisfy the LCO. When such a specified time interval is included in the ActionRequirements, the completion of a missed surveillance within this time intervalsatisfies Specification 4.0.3.O STATEMENT OF PROBLEMSome Action Requirements have allowable outage time limits of only one or twohours and do not establish a practical time limit for the completion of a missedSurveillance Requirement. If surveillances cannot be completed within these-3 -
time limits, a plant shutdown would usually be required. Even if the ActionRequirements include remedial measures that would permit continued operation,they may be stated In such a way that they could prevent the performance of therequired surveillance. A plant shutdown would also be required if the missedsurveillance applies to more than the minimum number of systems or componentsrequired to be operable for operation under the allowable outage time limits ofthe Action Requirements. In this case, the individual specification orSpecification 3.0.3 would require a shutdown.If a plant shutdown is required before a missed surveillance is completed, it islikely that it would be conducted when the plant Is being shut down becausecompletion of a missed surveillance would terminate the shutdown requirement.This is undesirable since it increases the risk to the plant and public safetyfor two reasons. First, the plant would be in a transient state Involvingchanging plant conditions that offer the potential for an upset that could leadto a demand for the system or component being tested. This would occur when thesystem or component is either out of service to allow performance of thesurveillance test or there is a lower level of confidence in its operabilitybecause the normal surveillance interval was exceeded. If the surveillance diddemonstrate that the system or component was inoperable, it usually would bepreferable to restore it to operable status before making a major change inplant operating conditions. Second, a shutdown would increase the pressure onthe plant staff to expeditiously complete the required surveillance so that theplant could be returned to power operation. This would further increase thepotential for a plant upset when both the shutdown and surveillance activitiesplace a demand on the plant operators.0 STAFF POSITIONIt is overly conservative to assume that systems or components are inoperablewhen a surveillance requirement has not been performed. The opposite is in factthe case; the vast majority of surveillances demonstrate that systems orcomponents in fact are operable. When a surveillance is missed, it is primarilya question of operability that has not been verified by the performance of therequired surveillance. Because the allowable outage time limits of some ActionRequirements do not provide an appropriate time limit for performing a missedsurveillance before shutdown requirements may apply, the TS should include atime limit that would allow a delay of the required actions to permit theperformance of the missed surveillance.This time limit should be based on considerations of plant conditions, adequateplanning, availability of personnel, the time required to perform thesurveillance, as well as the safety significance of the delay in completion ofthe surveillance. After reviewing possible limits, the staff has concludedthat, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limitfor completing a missed surveillance when the allowable outage times of theAction Requirements are less than this time limit or when shutdown ActionRequirements apply. The 24-hour time limit would balance the risks associatedwith an allowance for completing the surveillance within this period against therisks associated with the potential for a plant upset and challenge to safetysystems when the alternative is a shutdown to comply with Action Requirementsbefore the surveillance can be completed.-4 -
- i t SAlthough a missed surveillance would generally be completed in less time thanthis 24-hour limit allows, special circumstances may require additional time toensure that the surveillance can be conducted in a safe manner. The timelimits of Action Requirements for surveillances should start when it isidentified that Surveillance Requirements have not been performed, except whenthe 24-hour delay is allowed in the implementation of the Action Requirements.Where the 24-hour time limit is allowed, the time limits of the Action -Requirements are applicable either at the end of the 24-hour limit if thesurveillance has not been completed or at the time the surveillance isperformed if the system or component is found to be inoperable.Several issues need to be clarified regarding the additional 24-hour timelimit. First, this limit does not waive compliance with Specification 4.0.3.Under Specification 4.0.3, the failure to perform a Surveillance Requirementwill continue to constitute noncompliance with the Operability Requirements ofan LCO and to bring into play the applicable Action Requirements.Second, Specifications 3.0.2 and 4.0.3 should not be misinterpreted.Specification 3.0.2 notes that a TS is being complied with when the ActionRequirements are met within the specified time intervals. AlthoughSpecification 4.0.2 provides an allowance for extending the surveillanceinterval and allows for the completion of the surveillance within this timeinterval without violation of this Specification, under Specification 4.0.3nonperformance of a Surveillance Requirement, within the allowed surveillanceinterval defined by Specification 4.0.2, constitutes a violation of theOperability Requirements of an LCO, as defined by Specification 4.0.3, and issubject to enforcement action.To avoid any conflict among or misreading of Specffications 3.0.2, 4.0.3, and4.0.2, the staff wishes to make clear (1) that Specification 3.0.2 shall not beconstrued to imply that the completion of a missed surveillance within theallowable outage time limits of the Action Requirements -- whether or not theadditional 24-hour time limit is included -- negates the violation ofSpecification 4.0.3, and (2) that the failure to perform a surveillance withinthe allowable surveillance interval defined by Specification 4.0.2 constitutesa reportable event under 10 CFR 50.73(a)(2)(1)(B) because it is a conditionprohibited by the plant's TS.Third, even though an additional 24-hour time limit may apply for missedsurveillances, another consideration is the possibility that plant conditionsmay preclude the performance of the specified requirements. The provision of a24-hour delay in the application of the Action Requirements for the completionof a missed surveillance would provide time to obtain a temporary waiver of aSurveillance Requirement that could not otherwise be completed because ofcurrent plant conditions. If a surveillance can be performed only when theplant is shut down, there are only two options available to licensees when amissed surveillance is discovered during power operation and continuedoperation is not allowed under the Action Requirements. The first is to shutdown the plant and perform the required surveillance. The other option is toseek relief from the Surveillance Requirement. Such relief would result in theprocessing of a TS amendment. As a matter of existing policy, a temporarywaiver of compliance with a TS that would unnecessarily require a shutdown or-5 -
delay startup absence of some relief may be granted by NRC. A temporarywaiver of compliance may be granted if the licensee has demonstrated in awritten submittal, provided before the TS LCO expired, that the facility cansafely continue to operate without compliance with the TS during the time itwill take to process the TS amendment request.° CHANGE TO SPECIFICATION 4.0.3Specification 4.0.3 will be revised as follows to clarify when a missedsurveillance constitutes a violation of the Operability Requirements of an LCOand to clarify the applicability of the Action Requirements and the time duringwhich the limits apply:"Failure to perform a Surveillance Requirement within the allowedsurveillance interval, defined by Specification 4.0.2, shall constitutenoncompliance with the OPERABILITY requirements for a Limiting Conditionfor Operation. The time limits of the ACTION requirements are applicableat the time it is identified that a Surveillance Requirement has not beenperformed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> topermit the completion of the surveillance when the allowable outage timelimits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."Specification 4.0.3 previously included the statement that exceptions to it arestated in individual specifications. This statement is deleted becauseSpecification 4.0.3 Is always applicable, i.e., the implied exceptions forindividual specifications do not exist.Problem 13 -- CONFLICTS BETWEEN SPECIFICATIONS 4.0.3 AND 4.0.4RELATED TO MODE CHANGES (Specification 4.0.4)There are two parts of the general problem of conflicts between Specifications4.0.3 and 4.0.4 related to mode changes. Each of these parts is discussedseparately below.Part 1 -- SURVEILLANCE REQUIREMENTS THAT BECOME APPLICABLE DUE TO ACTIONREQUIREMENTS0 STATEMENT OF THE PROBLEMSpecification 4.0.4 prohibits entry into an operational mode or other specifiedcondition when Surveillance Requirements have not been performed within thespecified surveillance interval. First, a conflict with this TS exists when amode change is required as a consequence of shutdown Action Requirements andwhen the Surveillance Requirements that become applicable have not beenperformed within the specified surveillance interval. For instance, the plantcould previously have been in a mode for which the Surveillance Requirementswere not applicable and, therefore, the surveillance may not have been performedwithin the specified time interval. Consequently, the Action Requirements ofthe LCO associated with these Surveillance Requirements apply and the unit mayhave to be placed in a lower mode of operation than that required by theoriginal shutdown Action Requirements, or other remedial actions may have to be-6 -
taken, if the surveillance cannot be completed within the time limits forthese actions. This is a second problem that may be encountered.The first problem arises because conformance with Specification 4.0.4 wouldrequire the performance of these surveillances before entering a mode for whichthey apply. Source and intermediate range nuclear instrumentation and coldoverpressure protection systems in PWRs are examples of systems for whichSurveillance Requirements may become applicable as a consequence of modechanges to comply with shutdown Action Requirements. The second problem hasbeen mitigated by the change in Specification 4.0.3 to permit a delay of up to24 hours in the applicability of the Action Requirements, thereby placing anappropriate time limit on the completion of Surveillance Requirements thatbecome applicable as a consequence of mode changes to comply with ActionRequirements. However, the first problem can be further resolved by a changeto Specification 4.0.4.e C STAFF POSITIONThe potential for a plant upset and challenge to safety systems is heightened ifsurveillances are performed during a shutdown to comply with Action Requirements.It is not the intent of Specification 4.0.4 to prevent passage through or tooperational modes to comply with Action Requirements and it should not applywhen mode changes are imposed by Action Requirements. Accordingly,Specification, 4.0.4 should be modified to note that its provisions shall notprevent passage through or to operational modes as required to comply withAction Requirements. A similar provision is included in Specification 3.0.4.0 CHANGE TO SPECIFICATION 4.0.4The following will clarify Specification 4.0.4 for mode changes as a consequenceof Action Requirements:*This provision shall not prevent passage through or to OPERATIONAL MODESas required to comply with ACTION Requirements.Part 2 -- SURVEILLANCE REQUIREMENTS FOR EXCEPTIONS TO SPECIFICATION 4.0.40 STATEMENT OF THE PROBLEMAn exception to Specification 4.0.4 is allowed when Surveillance Requirementscan be completed only after entry into a mode or specified condition for whichthey apply. For example, the TS on power distribution limits are generallyexempt from Specification 4.0.4. However, upon entry into the mode orspecified condition, Specification 4.0.3 may not be met because theSurveillance Requirements may not have been performed within the allowedsurveillance interval. Generally, these Surveillance Requirements apply toredundant systems, and Specification 3.0.3 would apply because they are treatedas inoperable under Specification 4.0.3. Therefore, allowance of an exceptionto Specification 4.0.4 can create a conflict with Specification 4.0.3.-7 -
..I° STAFF POSITIONIt is not the intent of Specification 4.0.3 that the Action Requirements shouldpreclude the performance of surveillances when an exception to Specification4.0.4 is allowed. However, since Specification 4.0.3 has been changed to permita delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, anappropriate time limit now exists for the completion of those SurveillanceRequirements that become applicable when an exception to Specification 4.0.4 isallowed.-8 -
Enclosure 2 to Generic Letter 87-093/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS3/4.0 APPLICABILITY[NOTE: Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, asshown In the underlined provisions. The other specifications are shown forinformation only.]LIMITING CONDITIONS FOR OPERATION3.0.1 Compliance with the Limiting Conditions for Operation contained in thesucceeding specifications is required during the OPERATIONAL MODES or otherconditions specified therein; except that upon failure to meet the LimitingConditions for Operation, the associated ACTION requirements shall be met.3.0.2 Noncompliance with a specification shall exist when the requirements ofthe Limiting Condition for Operation and associated ACTION requirements arenot met within the specified time intervals. If the Limiting Condition forOperation is restored prior to expiration of the specified time intervals,completion of the ACTION requirements is not required.3.0.3 When a Limiting Condition for Operation is not met, except as providedin the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiatedto place it, as applicable, in:a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, andc. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.Where corrective measures are completed that permit operation under the ACTIONrequirements, the action may be taken in accordance with the specified timelimits as measured from the time of failure to meet the Limiting Condition forOperation. Exceptions to these requirements are stated in the individualspecifications.This specification is not applicable in MODES 5 or 6.3.0.4 Entry Into an OPERATIONAL MODE or other specified condition shall notbe made when the conditions for the Limiting Conditions for Operation are notmet and the associated ACTION requires a shutdown if they are not met withT-naspecifie time interval. Entry into anOPERATIONAL MODE or secifiedCondition maX be made in accordance with ACTION requirements when conformanceto them permits continued operation of the facility for an unlimited periodof time. This provision shall not prevent passage trough or to OPERATIONALMODES as required to comply with ACTION requirements. Exceptions to theserequirements are stated in the individual specifications.PWR STS3/4.0-1 APPLICABILITYSURVEILLANCE REQUIREMENTS4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODESor other conditions specified for individual Limiting Conditions forOperation unless otherwise stated in an individual Surveillance Requirement.4.0.2 Each Surveillance Requirement shall be performed within the specifiedtime interval with:a. A maximum allowable extension not to exceed 25% of the surveillanceinterval, butb. The combined time interval for any three consecutive surveillanceintervals shall not exceed 3.25 times the specified surveillanceinterval.4.0.3 Failure to perform a Surveillance Requirement within the allowedsurveillance interval, defined by Specification 4.0.2, shall constitutenoncompliance with the OPERABILI TY requirements for a Limiting Conditionfor Operation. The time limits of the ACTION requirements are applicableat the time it is identified that a Surveillance Requirement has not beenperformed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> topermit the completion of the surveillance when the allowable outage timelimits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. SurveillanceRequirements do not have to be performed on inoperjble equipment.4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall notbe made unless the Surveillance Requirement(s) associated with a LimitingCondition of Operation has been performed within the stated surveillanceinterval or as otherwise specified. This provision shall not pervent passagethrough or to OPERATIONAL MODES as required to comply with ACTION requirements.4.0.5 Surveillance Requirements for inservice inspection and testing of ASMECode Class 1, 2, and 3 components shall be applicable as follows:a. Inservice inspection of ASME Code Class 1, 2, and 3 components andinservice testing of ASME Code Class 1, 2, and 3 pumps and valvesshall be performed in accordance with Section XI of the ASME Boilerand Pressure Vessel Code and applicable Addenda as required by 10CFR 50, Section 50.55a(g), except where specific written relief hasbeen granted by the Commission pursuant to 10 CFR 50, Section50.55a(g)(6)(i).b. Surveillance intervals specified in Section XI of the ASME Boilerand Pressure Vessel Code and applicable Addenda for the inserviceinspection and testing activities required by the ASME Boiler andPWR STS3/4.0-2 a- t. s vAPPLICABILITYSURVEILLANCE REQUIREMENTSPressure Vessel Code and applicable Addenda shall be applicable asfollows in these Technical Specifications:ASME Boiler and Pressure VesselCode and applicable Addendaterminology for inserviceinspection and testing activitiesweeklyMonthlyQuarterly or every 3 monthsSemiannually or every 6 monthsEvery 9 monthsYearly or annuallyRequired frequenciesfor performing inserviceinspection and testingactivitiesAt least once per 7 daysAt least once per 31 daysAt least once per 92 daysAt least once per 184 daysAt least once per 276 daysAt least once per 366 daysc. The provisions of Specification 4.0.2 are applicable to the aboverequired frequencies for performing inservice inspection and testingactivities.d. Performance of the above inservice inspection and testing activitiesshall be in addition to other specified Surveillance Requirements.e. Nothing in the ASME Boilerconstrued to supersede theSpecification.and Pressure Vessel Code shall berequirements Rf any TechnicalaPWR STS3/4.0-3 Enclosure 3 to Generic Letter 87-093/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS3/4.0 APPLICABILITY-LNOTE: This enclosure provides revised Bases for all specifications inSections 3.0 and 4.0.)BASESSpecification 3.0.1 through 3.0.4 establish the general requirements applicableto Limiting Conditions for Operation. These requirements are based on therequirements for Limiting Conditions for Operation stated in the Code ofFederal Regulations, 10 CFR 50.36(c)(2):"Limiting conditions for operation are the lowest functional capabilityor performance levels of equipment required for safe operation of thefacility. When a limiting condition for operation of a nuclear reactor is notmet, the licensee shall shut down the reactor or follow any remedial actionpermitted by the technical specification until the condition can be met."Specification 3.0.1 establishes the Applicability statement within eachindividual specification as the requirement for when (i.e., in whichOPERATIONAL MODES or other specified conditions) conformance to the LimitingConditions for Operation is required for safe operation of the facility. TheACTION requirements establish those remedial measures that must be takenwithin specified time limits when the requirements of a Limiting Condition forOperation are not met.There are two basic types of ACTION requirements. the first specifies theremedial measures that permit continued operation of the facility which is notfurther restricted by the time limits of the ACTION requirements. In thiscase, conformance to the ACTION requirements provides an acceptable level ofsafety for unlimited continued operation as long as the ACTION requirementscontinue to be met. The second type of ACTION requirement specifies a timelimit in which conformance to the conditions of the Limiting Condition forOperation must be met. This time limit is the allowable outage time torestore an inoperable system or component to OPERABLE status or for restoringparameters within specified limits. If these actions are not completed withinthe allowable outage time limits, a shutdown is required to place the facilityin a MODE or condition in which the specification no longer applies. It isnot intended that the shutdown ACTION requirements be used as an operationalconvenience which permits (routine) voluntary removal of a system(s) orcomponent(s) from service in lieu of other alternatives that would not resultin redundant systems or components being inoperable.The specified time limits of the ACTION requirements are applicable from thepoint in time it is identified that a Limiting Condition for Operation is notmet. The time limits of the ACTION requirements are also applicable when asystem or component is removed from service for surveillance testing orinvestigation of operational problems. Individual specifications may includea specified time limit for the completion of a Surveillance Requirement whenequipment is removed from service. In this case, the allowable outage timePWR STSB 3/4.0-1 .
--. .-3/4.0 APPLICABILITYBASES (Con't)limits of the ACTION requirements are applicable when this limit expires ifthe surveillance has not been completed. When a shutdown is required tocomply with ACTION requirements, the plant may have entered a MODE in which anew specification becomes applicable. In this case, the time limits of theACTION requirements would apply from the point in time that the newspecification becomes applicable if the requirements of the Limiting Conditionfor Operation are not met.Specification 3.0.2 establishes that noncompliance with a specification existswhen the requirements of the Limiting Condition for Operation are not met andthe associated ACTION requirements have not been implemented within thespecified time interval. The purpose of this specification is to clarify that(1) implementation of the ACTION requirements within the specified timeinterval constitutes compliance with a specification and (2) completion of theremedial measures of the ACTION requirements is not required when compliancewith a Limiting Condition of Operation is restored within the time intervalspecified in the associated ACTION requirements.Specification 3.0.3 establishes the shutdown ACTION requirements that must beimplemented when a Limiting Condition for Operation is not met and thecondition is not specifically addressed by the associated ACTION requirements.The purpose of this specification is to delineate the time limits for placingthe unit in a safe shutdown MODE when plant operation cannot be maintainedwithin the limits for safe operation defined by the Limiting Conditions forOperation and its ACTION requirements. It is not Wntended to be used as anoperational convenience which permits (routine) voluntary removal of redundantsystems or components from service in lieu of other alternatives that would notresult in redundant systems or components being inoperable. One hour isallowed to prepare for an orderly shutdown before initiating a change in plantoperation. This time permits the operator to coordinate the reduction inelectrical generation with the load dispatcher to ensure the stability andavailability of the electrical grid. The time limits specified to reach lowerMODES of operation permit the shutdown to proceed in a controlled and orderlymanner that is well within the specified maximum cooldown rate and within thecooldown capabilities of the facility assuming only the minimum requiredequipment is OPERABLE. This reduces thermal stresses on components of theprimary coolant system and the potential for a plant upset that could challengesafety systems under conditions for which this specification applies.If remedial measures permitting limited continued operation of the facilityunder the provisions of the ACTION requirements are completed, the shutdownmay be terminated. The time limits of the ACTION requirements are applicablefrom the point in time there was a failure to meet a Limiting Condition forOperation. Therefore, the shutdown may be terminated if the ACTIONrequirements have been met or the time limits of the ACTION requirements havenot expired, thus providing an allowance for the completion of the requiredactions.PWR STSB 3/4.0-2 3/4.0 APPLICABILITYBASES (Con't)The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be inthe COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE ofoperation. If the plant is in a lower MODE of operation when a shutdown isrequired, the time limit for reaching the next lower MODE of operation ap-plies. However, if a lower MODE of operation is reached in less time thanallowed, the total allowable time to reach COLD SHUTDOWN, or other applicableMODE, is not reduced. For example, if HOT STANDBY is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, thetime allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total timeto reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.Therefore, if remedial measures are completed that would permit a return toPOWER operation, a penalty is not incurred by having to reach a lower MODE ofoperation in less than the total time allowied.The same principle applies with regard to the allowable outage time limits ofthe ACTION requirements, if compliance with the ACTION requirements for onespecification results in entry into a MODE or condition of operation foranother specification in which the requirements of the Limiting Condition forOperation are not met. If the new specification becomes applicable in lesstime than specified, the difference may be added to the allowable outage timelimits of the second specification. However, the allowable outage time limitsof ACTION requirements for a higher MODE of operation may not be used to extendthe allowable outage time that Is applicable when a Limiting Condition forOperation is not met in a lower MODE of operation.The shutdown requirements of Specification 3.0.3 dA not apply in MODES 5 and6, because the ACTION requirements of individual specifications define theremedial measures to be taken.Specification 3.0.4 establishes limitations on MODE changes when a LimitingCondition for pIeration is not met. It precludes placing the facility in ahigher MODE of operation when the requirements for a Limiting Condition forOperation are not met and continued noncompliance to these conditions wouldresult in a shutdown to comply with the ACTION requirements if a change inMODES were permitted. The purpose of this specification is to ensure thatfacility operation Is not initiated or that higher MODES of operation are notentered when corrective action is being taken to obtain compliance with aspecification by restoring equipment to OPERABLE status or parameters tospecified limits. Compliance with ACTION requirements that permit continuedoperation of the facility for an unlimited period of time provides an accept-able level of safety for continued operation without regard to the status ofthe plant before or after a MODE change. Therefore, in this case, entry intoan OPERATIONAL MODE or other specified condition may be made in accordancewith the provisions of the ACTION requirements. The provisions of thisspecification should not, however, be interpreted as endorsing the failure toexercise good practice in restoring systems or components to OPERABLE statusbefore plant startup.PWR STSB 3/4.0-3 3/4.0 APPLICABILITYBASES (Con't)When a shutdown is required to comply with ACTION requirements, the provisionsof Specification 3.0.4 do not apply because they would delay placing thefacility in a lower MODE of operation.Specifications 4.0.1 through 4.0.5 establish the general requirementsapplicable to Surveillance Requirements. These requirements are based on theSurveillance Requ1rements stated in the Code of Federal Regulations,10 CFR 50.36(c)(3):'Surveillance requirements are requirements relating to test, calibra-tion, or inspection to ensure that the necessary quality of systems andcomponents is maintained, that facility operation will be within safetylimits, and that the limiting conditions of operation will be met.'Specification 4.0.1 establishes the requirement that surveillances must beperformed durtng the OPERATIONAL MODES or other conditions for which therequirements of the Limiting Conditions for Operation apply unless otherwisestated in an individual Surveillance Requirement. The purpose of this speci-fication is to ensure that surveillances are performed to verify the opera-tional status of systems and components and that parameters are within speci-fied limits to ensure safe operation of the facility when the plant is in aMODE or other specified condition for which the associated Limiting Conditionsfor Operation are applicable. Surveillance Requirements do not have to beperformed when the facility is in an OPERATIONAL MTDE for which the requirementsof the associated Limiting Condition for Operation do not apply unless otherwisespecified. The Surveillance Requirements associated with a Special TestException are only applicable when the Special Test Exception is used as anallowable exception to the requirements of a specification.Specification 4.0.2 establishes the conditions under which the specified timeinterval for Sur~vellance Requirements may be extended. Item a. permits anallowable extension of the normal surveillance interval to facilitatesurveillance scheduling and consideration of plant operating conditions thatmay not be suitable for conducting the surveillance; e.g., transient conditionsor other ongoing surveillance or maintenance activities. Item b. limits theuse of the provisions of item a. to ensure that it is not used repeatedly toextend the surveillance interval beyond that specified. The limits ofSpecification 4.0.2 are based on engineering judgment and the recognition thatthe most probable result of any particular surveillance being performed is theverification of conformance with the Surveillance Requirements. These provisionsare sufficient to ensure that the reliability ensured through surveillanceactivities is not significantly degraded beyond that obtained from thespecified surveillance interval.Specification 4.0.3 establishes the failure to perform a SurveillanceRequirement within the allowed surveillance interval, defined by the provisionsof Specification 4.0.2, as a condition that constitutes a failure to meet theOPERABILITY requirements for a Limiting Condition for Operation. Under thePWR STSB 3/4.0-4 3/4.0 APPLICABILITYBASES (Con't)provisions of this specification, systems and components are assumed to beOPERABLE when Surveillance Requirements have been satisfactorily performedwithin the specified time interval. However, nothing in this provision-is tobe construed as implying that systems or components are OPERABLE when they arefound or known to be inoperable although still meeting the SurveillanceRequirements. This specification also clarifies that the ACTION requirementsare applicable when Surveillance Requirements have not been completed withinthe allowed surveillance interval and that the time limits of the ACTIONrequirements apply from the point in time it is identified that a surveillancehas not been performed and not at the time that the allowed surveillanceinterval was exceeded. Completion of the Surveillance Requirement within theallowable outage time limits of the ACTION requirements restores compliancewith the requirements of Specification 4.0.3. However, this does not negatethe fact that the failure to have performed the surveillance within the allowedsurveillance interval, defined by the provisions of Specification 4.0.2, was aviolation of the OPERABILITY requirements of a Limiting Condition for Operationthat is subject to enforcement action. Further, the failure to perform asurveillance within the provisions of Specification 4.0.2 is a violation of aTechnical Specification requirement and is, therefore, a reportable event underthe requirements of 10 CFR 50.73(a)(2)(i)(B) because it is a conditionprohibited by the plant's Technical Specifications.If the allowable outage time limits of the ACTION requirements are less than24 hours or a shutdown is required to comply with ACTION requirements, e.g.,Specification 3.0.3, a 24-hour allowance is provided to permit a delay inimplementing the ACTION requirements. This provides an adequate time limit tocomplete Surveillance Requirements that have not been performed. The purposeof this allowance is to permit the completion of a surveillance before ashutdown is required to comply with ACTION requirements or before otherremedial measures would be required that may preclude completion of asurveillance. The basis for this allowance includes consideration for plantconditions, adequate planning, availability of personnel, the time required toperform the surveillance, and the safety significance of the delay in completingthe required surveillance. This provision also provides a time limit for thecompletion of Surveillance Requirements that become applicable as a consequenceof MODE changes imposed by ACTION requirements and for completing SurveillanceRequirements that are applicable when an exception to the requirements ofSpecification 4.0.4 is allowed. If-a surveillance is not completed within the24-hour allowance, the time limits of the ACTION requirements are applicable atthat time. When a surveillance is performed within the 24-hour allowance andthe Surveillance Requirements are not met, the time limits of the ACTIONrequirements are applicable at the time that the surveillance is terminated.Surveillance Requirements do not have to be performed on inoperable equipmentbecause the ACTION requirements define the remedial measures that apply.However, the Surveillance Requirements have to be met to demonstrate thatinoperable equipment has been restored to OPERABLE status.PWR STSB 3/4.0-5 3/4.0 APPLICABILITYBASES (Con't)Specification 4.0.4 establishes the requirement that all applicable surveillancesmust be met before entry into an OPERATIONAL MODE or other condition ofoperation specified in the Applicability statement. The purpose of thisspecification is to ensure that system and component OPERABILITY requirementsor parameter limits are met before entry into a MODE or condition for whichthese systems and components ensure safe operation of the facility. Thisprovision applies to changes in OPERATIONAL MODES or other specified conditionsassociated with plant shutdown as well as startup.Under the provisions of this specification, the applicable SurveillanceRequirements must be performed within the specified surveillance intervalto ensure that the Limiting Conditions for Operation are met during initialplant startup or following a plant outage.When a shutdown is required to comply with ACTION requirements, the provisionsof Specification 4.0.4 do not apply because this would delay placing thefacility in a lower MODE of operation.Specification 4.0.5 establishes the requirement that inservice inspection ofASME Code Class 1, 2, and 3 components and inservice testing of ASME CodeClass 1, 2, and 3 pumps and valves shall be performed in accordance with aperiodically updated version of Section XI of the ASME Boiler and PressureVessel Code and Addenda as required by 10 CFR 50.55a. These requirements applyexcept when relief has been provided in writing by the Commission.This specification includes a clarification of the frequencies for performingthe inservice inspection and testing activities required by Section XI of theASME Boiler and Pressure Vessel Code and applicable Addenda. This clarificationis provided to ensure consistency in surveillance intervals throughout theTechnical Specifications and to remove any ambiguities relative to thefrequencies for performing the required inservice inspection and testingactivities.Under the terms of this specification, the more restrictive requirements ofthe Technical Specifications take precedence over the ASME Boiler and PressureVessel Code and applicable Addenda. The requirements of Specification 4.0.4to perform surveillance activities before entry into an OPERATIONAL MODE orother specified condition takes precedence over the ASME Boiler and PressureVessel Code provision which allows pumps and valves to be tested up to oneweek after return to normal operation. The Technical Specification definitionof OPERABLE does not allow a grace period before a component, that is notcapable of performing its specified function, is declared inoperable and takesprecedence over the ASME Boiler and Pressure Vessel Code provision whichallows a valve to be incapable of performing its specified function for up to24 hours before being declared inoperable.PWR STSB 3/4.0-6 i=~* t *.Enclosure 4 to Generic Letter 87-093/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS3/4.0 APPLICABILITY[NOTE: Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, asshown In the underlined provisions. The other specifications are shown forinformation only.]LIMITING CONDITIONS FOR OPERATION3.0.1 Compliance with the Limiting Conditions for Operation contained in thesucceeding Specifications is required during the OPERATIONAL CONDITIONS orother conditions specified therein; except that upon failure to meet theLimiting Conditions for Operation, the associated ACTION requirements shall bemet.3.0.2 Noncompliance with a Specification shall exist when the requirements ofthe Limiting Condition for Operation and associated ACTION requirements are notmet within the specified time intervals. If the Limiting Condition forOperation is restored prior to expiration of the specified time intervals,completion of the ACTION requirements is not required.3.0.3 When a Limiting Condition for Operation is not met, except as providedin the associated ACTION requirements, within one hour action shall be initiatedto place the unit in an OPERATIONAL CONDITION in which the Specification doesnot apply by placing it, as applicable, in:1. At least STARTUP 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 SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.Where corrective measures are completed that permit operation under the ACTIONrequirements, the action may be taken in accordance with the specified timelimits as measured from the time of failure to meet the Limiting Condition forOperation. Exceptions to these requirements are stated in the individualSpecifications.This specification is not applicable in OPERATIONAL CONDITION 4 or 5.3.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shallnot be made when the conditions for the Limiting Conditions for Operation arenot met and the associated ACTION recuires a shutdown if they are not metwithin a specified time interval. Entry into an OPERATIONAL CONDITION orother specified condition may be made in accordance with the ACTION requirementswhen conformance to them permits continued opeaton of the facility for anunlimited period of time. This provision shall not prevent passage through orto OPERATIONAL CONDITIONS as required to comply with ACTION requirements.Exceptions to these requirements are stated in the individual Specifications.BWR STS3/4.0-1
- si'/~uAPPLICABILITYSURVEILLANCE REQUIREMENTS4.0.1 Surveillance Requirements shall be met during the OPERATIONALCONDITIONS or other conditions specified for individual Limiting Conditionsfor Operation unless otherwise stated in an individual SurveillanceRequirement.4.0.2 Each Surveillance Requirement shall be performed within the specifiedtime interval with: -a. A maximum allowable extension not to exceed 25% of the surveillanceinterval, butb. The combined time interval for any 3 consecutive surveillanceintervals shall not exceed 3.25 times the specified surveillanceinterval.4.0.3 Failure to perform a Surveillance Requirement within the allowedsurveillance interval, defined by Specification 4.0.2, shall constitutenoncompliance with the OPERABILITY requirements for a Limiting Conditionfor Operation. The time limits of the ACTION requirements are applicableat the time it is Identified that a Surveillance Requirement has not beenperformed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> topermit the completion of the surveillance when the allowable outage timelimits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. SurveillanceRequirements do not have to be performed on inoperable equipment.4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicablecondition shall not be made unless the Surveillance Requirement(s) associatedwith the Limiting Condition for Operation have been performed within the* applicable surveillance interval or as otherwise specified. This provisionshall not prevent passage through or to OPERATIONAL CONDITIONS as required tocomply with ACTION requirements.4.0.5 Surveillance Requirements for inservice inspection and testing of ASMECode Class 1, 2, and 3 components shall be applicable as follows:a. Inservice inspection of ASME Code Class 1, 2, and 3 components andinservice testing of ASME Code Class 1, 2, and 3 pumps and valvesshall be performed in accordance with Section XI of the ASME Boilerand Pressure Vessel Code and applicable Addenda as required by 10CFR 50, Section 50.55a(g), except where specific written relief hasbeen granted by the Commission pursuant to 10 CFR 50, Section50.55a(g)(6)(i).b. Surveillance intervals specified in Section XI of the ASME Boilerand Pressure Vessel Code and applicable Addenda for the inserviceinspection and testing activities required by the ASME Boiler andBWR STS3/4.0-2 i .IAPPLICABILITYSURVEILLANCE REQUIREMENTSPressure Vessel Code and applicable Addenda shall be applicable asfollows In these Technical Specifications:ASME Boiler and Pressure VesselCode and applicable Addendaterminology for inserviceinspection and testing activitiesWeeklyMonthlyQuarterly or every 3 monthsSemiannually or every 6 monthsEvery 9 monthsYearly or annuallyRequired frequenciesfor performing inserviceinspection and testingactivitiesAt least once per 7 daysAt least once per 31 daysAt least once per 92 daysAt least once per 184 daysAt least once per 276 daysAt least once per 366 daysc. The provisions of Specification 4.0.2 are applicable to the aboverequired frequencies for performing inservice inspection and testingactivities.d. Performance of the above inservice inspection and testing activitiesshall be in addition to other specified Surveillance Requirements.e. Nothing in the ASME Boiler and Pressure Vesselconstrued to supersede the requirements ;f anySpecification.Code shallTechnicalbeBWR STS3/4.0-3
' IEnclosure 5 to Generic Letter 87-093/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS3/4.0 APPLICABILITYLNOTE: This enclosure provides revised Bases for all specifications in.Sections 3.0 and 4.0.)BASESSpecifications 3.0.1 through 3.0.4 establish the general requirements applicableto Limiting Conditions for Operation. These requirements are based on therequirements for Limiting Conditions for Operation stated in the Code of FederalRegulations, 10 CFR 50.36(c)(2):"Limiting conditions for operation are the lowest functional capabilityor performance levels of equipment required for safe operation of thefacility. When a limiting condition for operation of a nuclear reactor is notmet, the licensee shall shut down the reactor or follow any remedial actionpermitted by the technical specification until the condition can be met."Specification 3.0.1 establishes the Applicability statement within eachindividual specification as the requirement for when (i.e., in whichOPERATIONAL CONDITIONS or other specified conditions) conformance to theLimiting Conditions for Operation is required for safe operation of thefacility. The ACTION requirements establish those remedial measures that mustbe taken within specified time limits when the requirements of a LimitingCondition for Operation are not met. It is not intended that the shutdownACTION requirements be used as an operational convpnience which permits(routine) voluntary removal of a system(s) or componentfs) from service inlieu of other alternatives that would not result in redundant systems orcomponents being inoperable.There are two basic types of ACTION requirements. The first specifies theremedial measures that permit continued operation of the facility which is notfurther restricted by the time limits of the ACTION requirements. In thiscase, conformance to the ACTION requirements provides an acceptable level ofsafety for unlimited continued operation as long as the ACTION requirementscontinue to be met. The second type of ACTION requirement specifies a timelimit in which conformance to the conditions of the Limiting Condition forOperation must be met. This time limit is the allowable outage time torestore an inoperable system or component to OPERABLE status or for restoringparameters within specified limits. If these actions are not completed withinthe allowable outage time limits, a shutdown is required to place the facilityin an OPERATIONAL CONDITION or other specified condition in which thespecification no longer applies.The specified time limits of the ACTION requirements are applicable from thepoint in time it is identified that a Limiting Condition for Operation is notmet. The time limits of the ACTION requirements are also applicable when asystem or component is removed from service for surveillance testing orinvestigation of operational problems. Individual specifications may includea specified time limit for the completion of a Surveillance Requirement whenBWR STSB 3/4.0-1 3/4.0 APPLICABILITYBASES (Con't)equipment is removed from service. In this case, the allowable outage timelimits of the ACTION requirements are applicable when this limit expires ifthe surveillance has not been completed. When a shutdown is required tocomply with ACTION requirements, the plant may have entered an OPERATIONALCONDITION in which a new specification becomes applicable. In this case, thetime limits of the ACTION requirements would apply from the point in time thatthe new specification becomes applicable if the requirements of the LimitingCondition for Operation are not met.Specification 3.0.2 establishes that noncompliance with a specification existswhen the requirements of the Limiting Condition for Operation are not met andthe associated ACTION requirements have not been implemented within thespecified time interval. The purpose of this specification is to clarify that(1) implementation of the ACTION requirements within the specified timeinterval constitutes compliance with a specification and (2) completion of theremedial measures of the ACTION requirements is not required when compliancewith a Limiting Condition of Operation is restored within the time intervalspecified in the associated ACTION requirements.Specification 3.0.3 establishes the shutdown ACTION requirements that must beimplemented when a Limiting Condition for Operation is not met and thecondition is not specifically addressed by the associated ACTION requirements.The purpose of this specification is to delineate the time limits for placingthe unit in a safe shutdown CONDITION when plant Operation cannot bemaintained within the limits for safe operation defined by the LimitingConditions for Operation and its ACTION requirements. It is not intended tobe used as an operational convenience which permits (routine) voluntary removalof redundant systems or components from service in lieu of other alternativesthat would not result in redundant systems or componts being inoperable. Onehour is allowed to prepare for an orderly shutdown before initiating a changein plant operation. This time permits the operator to coordinate the reductionin electrical generation with the load dispatcher to ensure the stability andavailability of the electrical grid. The time limits specified to reach lowerCONDITIONS of operation permit the shutdown to proceed in a controlled andorderly manner that is well within the specified maximum cooldown rate andwithin the cooldown capabilities of the facility assuming only the minimumrequired equipment is OPERABLE. This reduces thermal stresses on componentsof the primary coolant system and the potential for a plant upset that couldchallenge safety systems under conditions for which this specification applies.If remedial measures permitting limited continued operation of the facilityunder the provisions of the ACTION requirements are completed, the shutdownmay be terminated. The time limits of the ACTION requirements are applicablefrom the point in time there was a failure to meet a Limiting Condition forOperation. Therefore, the shutdown may be terminated if the ACTIONrequirements have been met or the time limits of the ACTION requirements havenot expired, thus providing an allowance for the completion of the requiredactions.BWR STSB 3/4.0-2
- .e3/4.0 APPLICABILITYBASES (Con't)The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be inCOLD SHUTDOWN when a shutdown is required during POWER operation. If theplant is in a lower CONDITION of operation when a shutdown is required, thetime limit for reaching the next lower CONDITION of operation applies.However, if a lower CONDITION of operation is reached In less time thanallowed, the total allowable time to reach COLD SHUTDOWN, or other OPERATIONALCONDITION, is not reduced. For example, if STARTUP is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, thetime allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> because the total timeto reach HOT SHUTDOWN is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.Therefore, if remedial measures are completed that would permit a return toPOWER operation, a penalty is not incurred by having to reach a lowerCONDITION of operation in less than the total time allowed.The same principle applies with regard to the allowable outage time limits ofthe ACTION requirements, if compliance with the ACTION requirements for onespecification results in entry into an OPERATIONAL CONDITION or condition ofoperation for another specification in which the requirements of the LimitingCondition for Operation are not met. If the new specification becomesapplicable in less time than specified, the difference may be added to theallowable outage time limits of the second specification. However, theallowable outage time limits of ACTION requirements for a higher CONDITION ofoperation may not be used to extend the allowable outage time that isapplicable when a Limiting Condition for Operation is not met in a lowerCONDITION of operation. AThe shutdown requirements of Specification 3.0.3 do not apply in CONDITIONS 4and 5, because the ACTION requirements of Individual specifications define theremedial measures to be taken.Specification 3.0.4 establishes limitations on a change in OPERATIONALCONDITIONS when a Limiting Condition for Operation is not met. It precludesplacing the facility in a higher CONDITION of operation when the requirementsfor a Limiting Condition for Operation are not met and continued noncomplianceto these conditions would result in a shutdown to comply with the ACTIONrequirements if a change in CONDITIONS were permitted. The purpose of thisspecification is to ensure that facility operation is not initiated or thathigher CONDITIONS of operation are not entered when corrective action is beingtaken to obtain compliance with a specification by restoring equipment toOPERABLE status or parameters to specified limits. Compliance with ACTIONrequirements that permit continued operation of the facility for an unlimitedperiod of time provides an acceptable level of safety for continued operationwithout regard to the status of the plant before or after a change inOPERATIONAL CONDITIONS. Therefore, in this case, entry into an OPERATIONALCONDITION or other specified condition may be made in accordance with theprovisions of the ACTION requirements. The provisions of this specificationshould not, however, be interpreted as endorsing the failure to exercise goodpractice in restoring systems or components to OPERABLE status before plantstartup.BWR STS B 3/4.0-3___- ---._.... -*_ ._* _ A._ _* .. -..** _ ... .nv f vn1o ir lant *1 ?V 3/4.0 APPLICABILITYBASES (Con't)When a shutdown is required to comply with ACTION requirements, the provisionsof Specification 3.0.4 do not apply because they would delay placing thefacility in a lower CONDITION of operation.Specifications 4.0.1 through 4.0.5 establish the general requirementsapplicable to Surveillance Requirements. These requirements are based on theSurveillance Requirements stated in the Code of Federal Regulations,10 CFR 50.36(c)(3)
- OSurveillance requirements are requirements relating to test,calibration, or inspection to ensure that the necessary quality of systems andcomponents is maintained, that facility operation will be within safetylimits, and that the limiting conditions of operation will be met."Specification 4.0.1 establishes the requirement that surveillances must beperformed during the OPERATIONAL CONDITIONS or other conditions for which therequirements of the Limiting Conditions for Operation apply unless otherwisestated In an individual Surveillance Requirement. The purpose of thisspecification is to ensure that surveillances are performed to verify theoperational status of systems and components and that parameters are withinspecified limits to ensure safe operation of the facility when the plant is inan OPERATIONAL CONDITION or other specified condition for which the individualLimiting Conditions for Operation are applicable. Surveillance Requirementsdo not have to be performed when the facility is is an OPERATIONAL CONDITIONfor which the requirements of the associated Limiting Condition for Operationdo not apply unless otherwise specified. The Surveillance Requirementsassociated with a Special Test Exception are only applicable when the SpecialTest Exception is used as an allowable exception to the requirements of aspecification.Specification 4.0.2 establishes the conditions under which the specified timeinterval for Surveillance Requirements may be extended. Item a. permits anallowable extension of the normal surveillance interval to facilitatesurveillance scheduling and consideration of plant operating conditions thatmay not be suitable for conducting the surveillance; e.g., transientconditions or other ongoing surveillance or maintenance activities. Item b.limits the use of the provisions of item a. to ensure that it is not usedrepeatedly to extend the surveillance interval beyond that specified. Thelimits of Specification 4.0.2 are based on engineering Judgment and therecognition that the most probable result of any particular surveillance beingperformed is the verification of conformance with the SurveillanceRequirements. These provisions are sufficient to ensure that the reliabilityensured through surveillance activities is not significantly degraded beyondthat obtained from the specified surveillance interval.Specification 4.0.3 establishes the failure to perform a SurveillanceRequirement within the allowed surveillance interval, defined by theprovisions of Specification 4.0.2, as a condition that constitutes a failureBWR STSB 3/4.0-4 1 R 6-.v ' .v '3/4.0 APPLICABILITYBASES (Con't)to meet the OPERABILITY requirements for a Limiting Condition for Operation.Under the provisions of this specification, systems and components are assumedto be OPERABLE when Surveillance Requirements have been satisfactorily performedwithin the specified time interval. However, nothing in this provision is tobe construed as implying that systems or components are OPERABLE when they arefound or known to be inoperable although still meeting the SurveillanceRequirements. This specification also clarifies that the ACTION requirementsare applicable when Surveillance Requirements have not been completed within theallowed surveillance interval and that the time limits of the ACTION requirementsapply from the point in time it is identified that a surveillance has not beenperformed and not at the time that the allowed surveillance interval was exceeded.Completion of the Surveillance Requirement within the allowable outage timelimits of the ACTION requirements restores compliance with the requirements ofSpecification 4.0.3. However, this does not negate the fact that the failureto have performed the surveillance within the allowed surveillance interval,defined by the provisions of Specification 4.0.2, was a violation of theOPERABILITY requirements of a Limiting Condition for Operation that is subjectto enforcement action. Further, the failure to perform a surveillance withinthe provisions of Specification 4.0.2 is a violation of a Technical Specificationrequirement and is therefore, a reportable event under the requirements of10 CFR 50.73(a)(2)(i)(B) because it is a condition prohibited by the plant'sTechnical Specifications.If the allowable outage time limits of the ACTION requirements are less than24 hours or a shutdown is required to comply with ACTION requirements, e.g.,Specification 3.0.3., a 24-hour allowance is provided to permit a delay inimplementing the ACTION requirements. This provides an adequate time limit tocomplete Surveillance Requirements that have not been performed. The purpose ofthis allowance is to permit the completion of a surveillance before a shutdownwould be required to comply with ACTION requirements or before other remedialmeasures would be required that may preclude the completion of a surveillance.The basis for this allowance includes consideration for plant conditions, adequateplanning, availability of personnel, the time required to perform the surveillance,and the safety significance of the delay in completing the required surveillance.This provision also provides a time limit for the completion of SurveillanceRequirements that become applicable as a consequence of CONDITION changesimposed by ACTION requirements and for completing Surveillance Requirementsthat are applicable when an exception to the requirements of Specification4.0.4 is allowed. If a surveillance is not completed within the 24-hourallowance, the time limits of the ACTION requirements are applicable at thattime. When a surveillance is performed within the 24-hour allowance and theSurveillance Requirements are not met, the time limits of the ACTIONrequirements are applicable at the time that the surveillance is terminated.Surveillance Requirements do not have to be performed on inoperable equipmentbecause the ACTION requirements define the remedial measures that apply.However, the Surveillance Requirements have to be met to demonstrate thatinoperable equipment has been restored to OPERABLE status.BWR STSB 3/4.0-5
- L3/4.0 APPLICABILITYBASES (Con't)Specification 4.0.4 establishes the requirement that all applicablesurveillances ust be met before entry into an OPERATIONAL CONDITION or othercondition of operation specified in the Applicability statement. The purposeof this specification is to ensure that system and component OPERABILITYrequirements or parameter limits are met before entry into an OPERATIONALCONDITION or other specified condition for which these systems and componentsensure safe operation of the facility. This provision applies to changes inOPERATIONAL CONDITIONS or other specified conditions associated with plantshutdown as well as startup.Under the provisions of this specification, the applicable SurveillanceRequirements must be performed within the specified surveillance intervalto assume that the Limiting Conditions for Operation are met during initialplant startup or following a plant outage.When a shutdown is required to comply with ACTION requirements, the provisionsof Specification 4.0.4 do not apply because this would delay placing thefacility in a lower CONDITION of operation.Specification 4.0.5 establishes the requirement that inservice inspection ofASIE Code Class l, 2, and 3 components and inservice testing of ASME CodeClass 1, 2, and 3 pumps and valves shall be performed in accordance with aperiodically updated versiHon of Section XI of the ASME Boiler and PressureVessel Code and Addenda as required by 10 CFR 50.55a. These requirementsapply except when relief has been provided in writ4ng by the Commission.This specification includes a clarification of the frequencies for performingthe inservice Inspection and testing activities required by Section XI of theASME Boiler and Pressure Vessel Code and applicable Addenda. Thisclarification is provided to ensure consistency in surveillance intervalsthroughout the Technical Specifications and to remove any ambiguities relativeto the frequencies for performing the required inservice inspection andtesting activities.Under the terms of this specification, the more restrictive requirements ofthe Technical Specifications take precedence over the ASME Boiler and PressureVessel Code and applicable Addenda. The requirements of Specification 4.0.4to perform surveillance activities before entry into an OPERATIONAL CONDITIONor other specified condition takes precedence over the ASME Boiler andPressure Vessel Code provision that allows pumps and valves to be tested up toone week after return to normal operation. The Technical Specificationdefinition of OPERABLE does not allow a grace period before a component, whichis not capable of performing its specified function, is declared Inoperableand takes precedence over the ASME Boiler and Pressure Vessel Code provisionthat allows a valve to be Incapable of performing its specified function forup to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.BWR STSB 3/4.0-6 J _ .GenericLetter No.LIST @. RECENTLY ISSUED GENERIC k.ITERSDate ofIssuanceSubjectI.ssued ToGL 87-08GL 87-07GL 87-06GL 87-05GL 87-04GL 87-03GL 87-02IMPLEMENTATION OF 10 CFR 73.55MISCELLANEOUS AMENDMENTS ANDSEARCH REQUIREMENTSINFORMATION TRANSMITTAL OFFINAL RULEMAKING FOR REVISIONSTO OPERATOR LICENSING-IOCFR55AND CONFORMING AMENDMENTSTESTING OF PRESSURE ISOLATIONVALVESREQUEST FOR ADDITIONALINFORMATION-ASSESSMENT OFLICENSEE MEASURES TO MITIGATEAND/OR IDENTIFY POTENTIALDEGRADATION MKITEMPORARY EXEMPTION FROMPROVISIONS OF THE FBI CRIMINALHISTORY RULE-FOR TEMPORARYWORKERSVERIFICATION OF SEISMICADEQUACY OF MECHANICAL ANDELECTRICAL EQUIPTMENT INOPERATING REACTORS, USI A-46VERIFICATION OF SEISMICADEQUACY OF MECHANICAL ANDELECTRICAL EQUIPMENT INOPERATING REACTORS (USI A-46)05/11/8703/19/8703/13/8703/12/8703/06/8702/26/8702/19/87ALL POWERREACTORLICENSEESALL FACILITYLICENSEESALL OPERATINGREACTORLICENSEESLICENSEES OFOR'S,APPLICANTS FOROL'S, ANDHOLDERS OFCP'S FOR BWRMARK ICONTAINMENTSALL POWERREACTORLICENCESALL LICENSEESNOT SUBJECT TOUSI A-46REQUIREMENTSALL HOLDERS OFOPERATINGLICENSES NOTREVIEWED TOCURRENTLICENSINGCRITERIA ONSEISMICQUALIFICATIONOF EQUIPMENTGL 87-01PUBLIC AVAILABILITY OF THE NRC 01/08/87OPERATOR LICENSING EXAMINATIONQUESTION BANKALL POWERREACTORLICENSEES ANDAPPLICANTS FORAN OPERATINGLICENSE
-3-surveillance interval. Specification 4.0.4 should not be used to preventpassage through or to operational modes as required to comply with ActionRequirements because to do so: (a) would increase the potential for a plantupset; and (b) would challenge safety systems. Also, certain surveillancesshould be allowed to be performed during a shutdown to comply with ActionRequirements. Along with the modification of Specification 4.0.3 to permit adelay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of Action Requirements,Specification 4.0.4 has been clarified to allow passage through or tooperational modes as required to comply with Action Requirements.A second conflict could arise because, when Surveillance Requirements can onlybe completed after entry into a mode or specified condition for which theSurveillance Requirements apply, an exception to the requirements ofSpecification 4.0.4 is allowed. However, upon entry into this mode orcondition, the requirements of Specification 4.0.3 may not be met because theSurveillance Requirements may not have been performed within the allowedsurveillance interval. Therefore, to avoid any conflict between Specifications4.0.3 and 4.0.4, the staff wants to make clear: (a) that it is not the intentof Specification 4.0.3 that the Action Requirements preclude the performance ofsurveillances allowed under any exception to Specification 4.0.4; and (b) thatthe delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability ofAction Requirements now provides an appropriate time limit for the completionof those Surveillance Requirements that become applicable as a consequence ofallowance of any exception to Specification 4.0.4.If you have any questions on this matter, please contact your project manager.
Sincerely,Frank J. Miraglia, Associate Directorfor ProjectsOffice of Nuclear Reactor Regulation
Enclosures:
As stated(SECTIONS 3.0 AND 4.0): DOEA:NRR TSB:DpEA:NRR CEA:NRR-7'9Gunjxing DC her u her CERo0s1 105/ /7/87 05fit%/87 05/il /87 05/L//87AD:A 4R ADP:NRRRWSta stecki FJMiraglia05/Z.LP/87 05/ /87