Section 1 and 3 of Tech Specs should have discussions about use and interpretation of surveillances, required actions, and 25% grace period. You may also have that logic carried over into your ODCM.
The 25% grace period may not apply to all surveillances and that should already be clearly described in one of those sections. You should find different logic for surveillances required to be performed “once” or “once per” some frequency. I’ve not seen any application of the surveillance 25% grace logic typically found in TS 3.0.2 for “required actions” when a surveillance fails. Those 25% values appear in phrases related to “surveillances” and not “required actions”. Your ODCM is an extension of your TS, so I’d apply those in TS and copy the relevant content into your ODCM so it is clear to all. Haven’t seen any other NRC clarifying doc to provide relief to the logic typically used in TS. Some apply an admin frequency that is more restrictive than the ODCM to provide margin, so even if you violate your procedure, you still get that sample within the period in the ODCM. Your Reg Assurance guys will have the answer and can quickly point you to the right sections of your TS. Glen Vickers, CHP Exelon Corp RP Technical Lead 815-216-2723 (work/cell) From: Noble, Douglas L [mailto:[email protected]] Sent: Saturday, February 13, 2016 5:55 AM To: Eric Goldin; [email protected] Subject: RE: [powernet] 25% interval extension in RETS/ODCM Eric… have to use the “b” word but I don’t believe the allowance applies to comp actions. From: Eric Goldin [mailto:[email protected]] Sent: Saturday, February 13, 2016 12:42 AM To: [email protected]<mailto:[email protected]> Subject: [powernet] 25% interval extension in RETS/ODCM With respect to ODCM requirements, Tech Specs often allow a 25% extension for surveillance intervals. If a surveillance fails such that you enter an action statement, do any of you apply that 25% extension to the length of time the action statement requires as well? For example, if a radiation monitor surveillance must be completed once every 24 hours, the Tech Spec extension allows up to 6 extra hours to conduct the surveillance as long as the extensions are not added up over time. But if the surveillance fails, and an action statement is entered that says “take a sample every 24 hours”, do you also get to extend that interval to 30 hours for the sample? Thanks, Eric M Goldin, CHP [email protected]<mailto:[email protected]> Sent from my Verizon Wireless 4G LTE smartphone ________________________________ ________________________________ The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately, and delete the original message. This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to which it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -EXCIP
