Text

Transmittal of TSTF-512, Revision 0, Revise SR 3.0.3 to Address SRs That Cannot Be Performed or Are Not Met.
	ML082880503
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/14/2008
From:	David Bice, Gambrell R, Joseph Messina, Yates B; BWR Owners Group, Joint Owners' Group, PWR Owners Group, Technical Specifications Task Force
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-08-18 TSTF-512, Rev 0
	Download: ML082880503 (53)
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TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY October 14, 2008 TSTF-08-18 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-512, Revision 0, "Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met"

Dear Sir or Madam:

Enclosed for NRC review is TSTF-512, Revision 0, "Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met." TSTF-512 is applicable to all plant types.

Any NRC review fees associated with the review of TSTF-512 should be billed to the Boiling Water Reactor Owners Group.

The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.

Should you have any questions, please do not hesitate to contact us.

Bert Yates (PWROG/W) John Messina (BWROG)

David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W)

Enclosure cc: Robert Elliott, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administered by EXCEL Services Corporation

WOG-194, Rev. 0 TSTF-512, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met NUREGs Affected: 1430 1431 1432 1433 1434 Classification 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Not Exempt Benefit: Increases Equipment Operability Industry

Contact:

Bert Yates, (314) 225-1702, gyates@ameren.com See attached justification.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by: PWROG LSC Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 01-Mar-08 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 15-Sep-08 TSTF Review Information TSTF Received Date: 22-Sep-08 Date Distributed for Review 22-Sep-08 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 14-Oct-08 NRC Review Information NRC Received Date: 14-Oct-08 Affected Technical Specifications SR 3.0.1 SR Applicability 14-Oct-08 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-194, Rev. 0 TSTF-512, Rev. 0 SR 3.0.1 Bases SR Applicability SR 3.0.3 SR Applicability SR 3.0.3 Bases SR Applicability SR 3.0.4 Bases SR Applicability 14-Oct-08 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-512, Rev. 0 1.0 Description SR 3.0.3 provides an allowance for surveillances that are missed. The proposed Traveler revises SR 3.0.3 to move the existing allowance to SR 3.0.3.a. A new allowance that addresses Surveillances that cannot be performed within the Specified Frequency is added as SR 3.0.3.b. A new allowance that addresses the situation of an SR that is not met but the associated LCO is otherwise met is included as a new SR 3.0.3.c. SR 3.0.1 is modified to state that SR 3.0.3 provides an exception to that requirement.

2.0 Proposed Change SR 3.0.3 is revised to have three parts. SR 3.0.3.a is the same as the existing SR 3.0.3.

SR 3.0.3.b addresses the situation in which it is discovered that an SR cannot be performed before the expiration of the specified Frequency. SR 3.0.3.c addresses the situation in which it is discovered that an SR is not met but the LCO is still met.

SR 3.0.1 is revised to reference the exception provided by the revised SR 3.0.3.

The SR 3.0.3 Bases are revised to provide discussion of the proposed changes. In addition, a paragraph is added discussing the application of SR 3.0.3 (as proposed SR 3.0.3.a) to Surveillances that have never been performed. This discussion incorporates existing industry guidance.

The SR 3.0.1 and SR 3.0.4 Bases are revised to address the exceptions provided by SR 3.0.3.

3.0 Background

TSTF-358-A, Revision 6, "Missed Surveillance Requirements," was approved by the NRC on September 28, 2001. TSTF-358 was a risk-informed change that allowed a longer period to perform missed Surveillances. All but two sites in the U.S. have adopted TSTF-358-A.

SR 3.0.3 provides an allowance for surveillances that are missed. In other words, if it is discovered that a Surveillance was not performed within the specified Frequency, SR 3.0.3 provides time to perform the SR before declaring the SR not met.

There is a situation that has a similar safety significance to a missed Surveillance that is not addressed in SR 3.0.3. If it is discovered that a Surveillance cannot be performed prior to the expiration of the specified Frequency, there is no recourse but to declare the SR not met when the specified Frequency expires. For example, a broken sample valve may prevent taking a reactor coolant system (RCS) sample to measure RCS activity. If this is discovered one minute after the specified Frequency of the Surveillance is expired, then SR 3.0.3 allows up to the Frequency to perform the Surveillance (assuming a risk assessment supports the extension). If, however, it is discovered one minute before the specified Frequency is expired, there is no allowance and the Surveillance must be Page 2

TSTF-512, Rev. 0 declared not met, the LCO must be declared not met, and the Required Actions followed (up to and including a plant shutdown).

Another situation regarding the performance of Surveillances to be addressed is when a Surveillance is not met but the associated LCO is still met. In accordance with 10 CFR 50.36, the purpose of SRs is to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. However, in some limited circumstances a Surveillance may not be met but the associated LCO may still be met. For example, a Surveillance may require automatic actuation of a component. If the component is secured in the post-accident condition, and no subsequent change of state is required for accident mitigation, the associated system may be Operable (i.e., capable of performing its specified safety function(s)). However, SR 3.0.1 would require declaring the LCO not met, and the Required Actions followed (up to and including a plant shutdown).

The proposed change addresses both of these situations with a change to SR 3.0.3.

4.0 Technical Analysis SR 3.0.3.a The proposed SR 3.0.3.a contains the same requirements as SR 3.0.3 as approved by the NRC in TSTF-358-A.

The Bases of SR 3.0.3.a are revised to provide a discussion of the application of SR 3.0.3.a to Surveillances that have never been performed. This discussion incorporates existing industry guidance which provides restrictions on the use of SR 3.0.3.a in this situation. SR 3.0.3.a may be applied if it has been discovered that an SR (or a portion of an SR) has never been performed provided that there is a reasonable expectation that the associated equipment is OPERABLE or that variables are within limit, and that it is expected that the SR will be met when performed. An example would be a relay contact that has never been tested in accordance with a particular SR, but the adjacent, physically connected relay contacts have been tested, the relay contacts have been tested by another SR, or historical operation of the associated equipment would have indicated a failure of the relay contact.

SR 3.0.3.b The accident analyses presented in the UFSAR do not address the performance of Surveillance Requirements. The accident analyses assume that the necessary equipment is available and then, in most cases, assumes the single most limiting active failure occurs.

Therefore, this proposal to extend the time allowed to perform a Surveillance that is met but cannot be performed within the specified Frequency would not affect the accident analyses, as long as the equipment was, in fact, Operable.

The risk of a Surveillance that cannot be performed within the specified Frequency and that of a Surveillance that is discovered to have not been performed within the specified Page 3

TSTF-512, Rev. 0 Frequency is exactly the same. In both cases, if there is reasonable assurance that the Surveillance will be met when performed, the delay time has the same effect.

Providing a delay time up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable period to allow performing the Surveillance given the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

A delay beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months must be assessed under the plant specific Probabilistic Safety Assessments (PSAs), which will consider the time between Surveillances as the longest period that a particular component may be inoperable without detection. This time period may be used in determining the component basic event (BE) failure probabilities for standby components. To evaluate the potential impact of a Surveillance that cannot be performed on plant risk, the component failure probability can be increased proportionally to the time interval from the last test to the next expected test of the component. This new component failure probability can then be factored into the PSA model and the impact on CDF and/or LERF can be determined.

It is expected that there are few standby components for which the inability to perform a Surveillance would result in a significant impact on plant risk as measured by CDF and LERF. Doubling component failure probabilities, assuming the Surveillance test interval doubled, results in only a few plant components providing a significant impact on risk.

The vast majority of the components have little or no impact on risk.

Additionally, the inability to perform a Surveillance is a rare occurrence, which when combined with the assumption that the equipment being tested is inoperable, results in a very small increase in plant risk.

For those Surveillances that are potentially risk-significant, the requirement to perform a risk evaluation if it is extended beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will ensure the risk remains acceptable.

So even though the historical data and typical PSA results show an overall small risk increase for this change, the risk evaluation requirements will ensure that the risk increase for a given Surveillance extension is also acceptable.

Overall, due to the avoidance of unnecessary shutdowns, the low number of potentially risk-significant Surveillances, and the requirement for a risk evaluation if a Surveillance is extended, the change is considered a risk reduction to risk neutral. Additionally, the change represents a burden reduction for both the plant and the NRC.

SR 3.0.3.c As discussed above, the accident analyses presented in the UFSAR do not address the performance of Surveillance Requirements. The accident analyses assume that the necessary equipment is available and then, in most cases, assumes the single most limiting active failure occurs. Therefore, the analysis is based on a system performing its specified safety function, not the particular performance of an SR.

Typically Surveillances are directly tied to the ability of a system to perform its specified safety function. For example, minimum pump flow, containment temperature, instrument channel calibrations, and shutdown margin are integral assumptions in the accident Page 4

TSTF-512, Rev. 0 analysis and to the Operability of the associated systems. However, there are some Surveillances that are not directly tied to the subject system being capable of performing its specified safety function. For example, ventilation system charcoal filters are typically bypassed during normal operation to extend the life of the charcoal bed. On receipt of an accident signal, dampers redirect air flow to the filters. If flow is directed to the filter at all times, the charcoal will need to be replaced more frequently but the ventilation system will be fully capable of performing its specified safety function. In another example, the automatic start signal of a pump may not be functional but the pump may be capable of being started manually within the time assumptions of the accident analysis, such that it is fully capable of performing its specified safety function should an accident occur. Regulatory Issue Summary 2005-20, "Operability Determinations &

Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," Appendix C.5, provides guidance on using manual action in lieu of automatic action. However, if a Surveillance explicitly requires testing of the automatic action, this guidance cannot be applied and the LCO is not met.

Application of SR 3.0.3.c requires a documented determination that, with the exception of the Surveillance, the LCO is met. SR 3.0.3.c cannot be used until the documented determination is complete. The documented determination must be retained and be available for NRC review. Therefore, if is discovered that a Surveillance is not met, the LCO must be declared not met and the appropriate Conditions entered until the documented determination is completed and SR 3.0.3.c may be used. If the Surveillance will not be met following a preplanned, temporary change to the plant, the documented determination may be available prior to the SR not being met. In that case, SR 3.0.3.c may be used as soon as the SR is not met.

The documentation that, with the exception of the Surveillance, the LCO is met must consider all aspects of meeting the LCO. If the LCO requires Operability, the documented determination must consider all aspects of Operability and all the specified safety functions, including those performed before and during an accident. The documented determination should consider the guidance in NRC Inspection Manual, Part 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety."

If it is documented that, with the exception of the Surveillance, the associated LCO is still met, then compliance with the requirement to declare the LCO not met may be delayed, from the time the Surveillance is not met up to the period of the specified Frequency, or until the Applicability of the Specification is entered following the next refueling outage, whichever is greater. This delay period provides adequate time to restore plant conditions so that the Surveillance may be met. The option of delaying performance until the next refueling outage is necessary due to the possibility that repairs required to support the test may require a shutdown to in order to complete. This is acceptable since the component required by the LCO will continue to be capable of performing its specified safety function during the delay period.

SR 3.0.3.c does not require a risk evaluation. PSAs consider system availability, not performance of Surveillances. If the associated system is capable of performing its Page 5

TSTF-512, Rev. 0 specified safety function, there will be no change to plant risk resulting from failure to meet the SR.

Use of SR 3.0.3.c is expected to be an infrequent occurrence. While a delay period up to the specified Frequency or the next refueling outage (e.g., entry into the Applicability of the Specification following entry into Mode 6 (PWRs) or Mode 5 (BWRs), whichever is greater, is provided to meet the Surveillance, it is expected that actions should be taken to meet the Surveillance at the first reasonable opportunity. All Surveillances that are not met will be placed in the licensees Corrective Action Program.

If at any time during the delay period it is determined that the LCO is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relaxes the time allowed to perform a Surveillance and provides the option to not meet an Surveillance provided the associated system is Operable. The performance of Surveillances is not an initiator to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be Operable and capable of performing the accident mitigation functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Page 6

TSTF-512, Rev. 0 Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change relaxes the time allowed to perform a Surveillance and provides the option to not meet an Surveillance provided the associated system is Operable. As supported by the historical data, the likely outcome of any Surveillance is verification that the LCO is met. Failure to perform a Surveillance within the prescribed Frequency does not cause equipment to become inoperable.

Similarly, relaxing the time to declare an associated system inoperable when a Surveillance cannot be met but it can be demonstrated that the associated system is Operable will have little effect on the margin of safety, which is more directly tied to the Operability of the equipment, not performance of the Surveillance.

The only effect of the additional time allowed to address Surveillances on the margin of safety is the small chance that a system documented to be Operable is not, in fact, found to be Operable. This must be balanced against the real risk of manipulating the plant equipment or establishing the plant conditions needed to perform or meet the Surveillance. In addition, parallel trains and alternate equipment are typically available to perform the safety function of the equipment not tested.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significant hazards considerations under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria Title 10 of the Code of Federal Regulations, Paragraph 50.36, requires Technical Specifications to contain Surveillances. It states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The proposed change addresses the actions to be take when Surveillances are not performed, or will not be performed within the specified Frequency, or if the Surveillance is not met. The regulations do not address these conditions and the proposed change does not violate the 50.36 requirement to have Surveillances.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions Page 7

TSTF-512, Rev. 0 regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Consideration A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 References None.

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TSTF-512, Rev. 0 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO except as provided in SR 3.0.3. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per . . ."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance is not met or was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, as described below. This is an exception to SR 3.0.1.

from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

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

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

a. If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be BWOG STS 3.0-4 Rev. 3.0, 03/31/04

TSTF-512, Rev. 0 SR Applicability 3.0 performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

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

b. If it is discovered that it will not be possible to perform a Surveillance within its specified Frequency due to conditions that prohibit the performance of the SR but do not render the SR not met, then compliance with the requirement to declare the LCO not met may be delayed, from the time the Surveillance is due to be performed, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the time the Surveillance is due to be performed and the risk impact shall be managed.

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

c. If it is discovered that a Surveillance is not met or will not be met and it is documented that the associated LCO is still met, then compliance with the requirement to declare the LCO not met may be delayed, from the time the Surveillance is not met up to the period of the specified Frequency, or until completion of the next scheduled refueling outage, whichever is greater. If at any time during the delay period it is determined that the LCO is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

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

SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

BWOG STS 3.0-5 Rev. 3.0, 03/31/04