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 No. 87-09)

                                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. 


8706090039 

                                     -2-

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 hours 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 plant 

                                    - 3 - 

upset; 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 hours 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 hours 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