NRC Generic Letter 87-09, Sections 3.0 and 4.0 of Standard Tech Specs on Limiting Conditions for Operation and Surveillance Requirements

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June 4, 1987

TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTS

Gentlemen:

SUBJECT: SECTIONS 3.0 AND 4.0 OF THE STANDARD TECHNICAL SPECIFICATIONS (STS) ON THE APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS (Generic Letter 87-09)

As a part of recent initiatives to improve Technical Specifications (TS),

the NRC, in cooperation with the Atomic Industrial Forum (AIF), has developed a program for TS improvements. One of the elements of this program is the implementation of short-term improvements to resolve immediate concerns that have been identified in investigations of TS problems by both NRC and AIF. The guidance provided in this generic letter addresses three specific problems that have been encountered with the general requirements on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the STS.

There are five enclosures to this Generic Letter. Enclosure 1 applies to both PWR and BWR STS and provides a complete discussion of the three problems and the staff's position on acceptable modifications of the TS to resolve them. These modifications should result in improved TS for all plants ind are consistent with the recommendations of NUREG-1024, "Technical Specifications Enhancing the Safety Impact" and the Commission Policy Statement on Technical Specification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 of the PWR and BWR STS, respectively, which incorporate the modifications being made by this Generic Letter. Enclosures 3 and 5:

(a) provide the staff's update of the bases for the PWR and BWR STS, respectively;

(b) reflect the modifications of Sections 3.0 and 4.0 of the STS; and

(c) include improved bases for the unchanged requirements in these sections.

The staff concludes that these modifications will result in improved TS for all plants. Licensees and applicants are encouraged to propose changes to their TS that are consistent with the guidance provided in the enclosures; however, these changes are voluntary for all licensees and current OL applicants.

The staff would like to point out three important points connected with the present TS effort. First, it is aware that the TS can be clarified, simplified, and streamlined both as a whole and with respect to the specifications that are the subject of this Generic Letter. Nonetheless, in keeping with its short-term and purposefully narrow focus, it decided to keep these proposed modifications:

(a) focused on the three problems;

(b) relatively simple; and

(c) consistent with the phrasing of existing TS. Second, after the resolution of these and other identified TS problems, the staff will notify licensees and applicants of its conclusions and resulting proposals for additional short-term TS improvements. Finally, the staff is not proposing to formally amend the STS at this time. Instead the changes will be factored into the development of the new STS anticipated as a part of the implementation of the Commission's Policy Statement on Technical Specification Improvements.

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The following is a summary of the three problems covered by the enclosures. The first problem involves unnecessary restrictions on mode changes by Specification 3.0.4 and inconsistent application of exceptions to it. The practical solution is to change this specification to define the conditions under which its requirements apply. With respect to unnecessary mode changes, Specification 3.0.4 unduly restricts facility operation when conformance with Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements. The solution also resolves the problem of inconsistent application of exceptions to Specification 3.0.4:

(a) which delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility; and

(b) which delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.

The second problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceeded. The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO. It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for performing a missed surveillance before Shutdown Requirements apply, the TS should include a time limit that allows a delay of required actions to permit the performance of the missed surveillance based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and, of course. the safety significance of the delay in completing the surveillance. The staff has 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 a missed surveillance when the allowable outage times of the Action Requirements are less than this limit, or when time is needed to obtain a temporary waiver of the Surveillance Requirement.

The third problem involves two possible conflicts between Specifications 4.0.3 and 4.0.4. The first conflict arises because Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. A conflict with this requirement exists when a mode change is required as a consequence of Action Requirements and when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interval. Specification 4.0.4 should not be used to prevent passage through or to operational modes as required to comply with Action Requirements because to do so:

(a) would increase the potential for a plantupset; and

(b) would challenge safety systems. Also, certain surveillances should be allowed to be performed during a shutdown to comply with Action Requirements. Along with the modification of Specification 4.0.3 to permit a 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 Action Requirements, Specification 4.0.4 has been clarified to allow passage through or to operational modes as required to comply with Action Requirements.

A second conflict could arise because, when Surveillance Requirements can only be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed. However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore, to avoid any conflict between Specifications 4.0.3 and 4.0.4, the staff wants to make clear:

(a) that it is not the intent of Specification 4.0.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to Specification 4.0.4; and

(b) that the 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 of Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of allowance 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 Director for Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated