3F0388-08, Application for Amend to License DPR-72,revising Tech Spec 4.0.2.b Requirement That Surveillance Requirement Be Performed W/Total Max Combined Interval Time for Any Three Consecutive Tests Not to Exceed Ref Interval by 3.25 Times
| ML20148A027 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/14/1988 |
| From: | Ken Wilson FLORIDA POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 3F0388-08, 3F388-8, A00L-880314, AL-880314, NUDOCS 8803160420 | |
| Download: ML20148A027 (2) | |
Text
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Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification 4.0.2.b
Dear Sir:
Technical Specification (TS) 4.0.2.b requires that each surveillance requirement be performed within the specified time interval with a total maximum combieed interval time for any 3 consecutive tests not to exceed 3.25 times the specified surveillance interval.
This requirement is currertly being applied literally.
However, this application neglects time spent in refueling outages.
As a result normal surveillance intervals end up being shortened to ensure coupliance with TS 4.0.2.b.
Refueling interval surveillances, for examole, have ended up being reduced from 18 months to 12 months.
This was due to the inclusion, in the surveillance due date calculation, of 6 months worth of refueling / maintenance outages that occurred within the previous 2 consecutive test intervals.
This practice has in the past caused FPC and NRC resources to be unnecessarily expended.
FPC does nat believe the intent of this specification was to cause normal surveillance intervals to be reduced.
Rather, its intent was to assure that allawable extensions to the surveillance interval were not abused.
Therefore, the following application is proposed.
The total interval time for any 3
consecutive tests would not include time spent during those intervals in non-applicable modes.
This total maximum conbined interval time for any 3 consecutive tests would then be limited to less than 3.25 times the specified surveillance interval.
This application is consistont with TS 4.0.1 which requires that surveillance requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation.
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I Post Office Box 219
- Crystal River, Flohda 32629
- Telephone (904) 795-3802
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d.,s March 14, 1988 3F0388-08 Page 2 FPC requests concurrence be provided concerning this proposed application of TS 4.0.2.b.
This proposed application meets the intent of the specification and will allow both FPC and NRC resources be better utilized.
Your attention in this matter is appreciated.
Should you have any questions please do not hesitate to contact this office.
Sincerely, tdb K.R.
Wilson Manager, Nuclear Licensing DGG/dhd xc:
Dr.
J.
Nelson Grace Regional Administrator, Region II Mr.
T.F.
Stetka Senior Resident Inspector
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