W3P89-1578, Application for Amend to License NPF-38,consisting of Tech Spec Change Request NPF-38-106,revising Tech Spec 4.0.2 Re Time in Which to Complete Surveillances
| ML20005D817 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/19/1989 |
| From: | Dewease J LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20005D818 | List: |
| References | |
| GL-89-14, W3P89-1578, NUDOCS 9001020003 | |
| Download: ML20005D817 (6) | |
Text
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W3P89-1578 A4.05 QA December 19, 1989 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPT-38 Technical Specification Change Request NPF-38-106 Gentlement The following justifies revising Technical Specification 4.0.2 concerning the time in which to complete surveillances. This proposal conforms with Generic Letter 89-14 by requesting the same words for Specification 4.0.2 and its bases.
Should you have any questions or comments on this matter, please feel free to contact L.W. Laughlin at (504) 464-3499.
Very truly yours.
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/LWL ssf A achmentst NPF-38-106 cc Messrs. R.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-NRR E.L. Blake W.M. Stevenson NRC Resident Inspectors Office Administrator Nucicar Energy Division (State of Louisiana)
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10F l
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ATFIDAVIT Y
J.G.~Dewcase, being duly sworn, hereby deposes and says that he is Senior Vice President - Nuclear Operations of Louisiana Power & Light Company;
'that he is duly authorized to sign and file with the Nuclear Regulatory
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Commission the attached Technical Specification Change Request NPF-38-106;.
that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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.G. Dewcase entor Vice President-Nuclear Operations STATE OF LOUISIANA)
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-106 The fol ow ng justif'aa 1
- vising Technical Specification 4.0.2 concerning l i the time in which to c_.>
e surveillances. This proposal conforms with Generic Letter 89-14 by regstating the same words for-Specification 4.0.2 and its bases.
Existing Specifications See Attachment A Proposed Specifications See Attachment B Description
- Specification 4.0.2 permits extending surveillance intervals up to twenty-five percent of the specified interval. This extension eases surveillance, scheduling.
It allows postponing surveillances when plant
. conditions are not suitable for conducting a surveillance, e.g., under transient conditions or other competing maintenance cecivities.
Specification 4.0.2 also limits extending surveillances so the combined time interval for any three consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval. The 3.25 limit precludes routinely extending a surveillance interval by twenty-five percent.
Commonwealch Edison Company (CECO) submitted a lead-plant proposal for the LaSalle Technical Specifications to remove the 3,25 limit for surveillances performed during a refueling outage with an eighteen-month surveillance frequency. After discussions with the NRC staff, CECO amended the proposal to remove the 3,25 ifmitation for all surveillances. The staff approved the amended proposal on a lead-plant basis. Consistent with NRC policy, Generje Letter 89-14 encourages other license amendment requests to implement this line-item improvement in Technical Specification.
Experience shows the eighteen-month surveillance frequency, with the provision to extend it by twenty-five percent, usually accommodates normal variations in fuel cycle leugth. However, the NRC staff routinely grants requests for one-time exceptions to the 3.25 limit on extending refueling surveillances because the safety effect is low in contrast to a forced shutdown to perform these surveillances.
Therefore, the 3.25 limit on surveillances has not proven a practical limit on the twenty-five percent allowance for surveillances coinciding with a refueling outage.
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p Thel allowance to extend surveillance intervals by twenty-five percent ;can y
'also result in a significant-safety benefit for surveillances performed on g:
L a routine basis during plant operation. This safety benefit arises when t
extending a surveillance deadline to a time when conditions are suitable i
for performing the surveillance. Examples of this include. transient plant operfting conditions or when safety systems are out of service because of Longoing maintenance activities. In such cases, the safety benefit derived y
~from the' twenty-five percent allowance outweighs any benefit obtained by 31?iting ' three consecutive surveillance intervals to the 3.25 limit. - Also.
an. administrative burden exists for tracking the twenty-five percent allowance to ensure compliance with the 3.25 limit. On the basis of these-considerations, the NRC concluded that removing the 3.25 limit has an overall positive impact on safo:f.
This proposal removes an unnecessary restriction on extending surveillance
. requirements and results in a. benefit to safety when plant. conditions are not conducive to the safe conduct of surveillance requirements. The-removal of the 3.25 limit provides greater flexibility in surveillance scheduling, reduces the corresponding administrative burden, and has a positive effect on safety.-
Safety Analysis Generic Letter 89-14 presents a review of the safety significance of the proposed changes to Technical Specifications 4.0.2.
The staff concluded l
that the proposed-changes are acceptable and do not require additional review. Therefore, ne significant hazards consideration exists.
The Commission provided guidance concerning standards for determining whether a significant hazards consideration exist a by. providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations. This proposal most closely resembles example (iv).
"(iv) A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating restriction and the
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cr1teria-to be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the criteria have been met."
Generic Letter 89-14 describes a line item improvement to technical specifications approved for LaSalle and applicable to Waterford. This proposal suggests incorporating the exact words from Generic Letter 89-14 for Specification 4.0.2 and its bases.
Safety and-Significant Hazards Determination
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Based'on the above Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined 2
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- ATTACHMENT A NPF-38-106
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