ML020800796
| ML020800796 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/18/2002 |
| From: | Mecredy R Rochester Gas & Electric Corp |
| To: | Clark R Document Control Desk, NRC/NRR/DLPM/LPD1 |
| References | |
| Download: ML020800796 (16) | |
Text
N A Subsidiary of RGS Energy Group, Inc.
14649-0001 ° 716 546-2700 www.rge.com ROCHESTER GAS AND ELECTRIC CORPORATION ° 89 EAST AVENUE, ROCHESTER, N.Y ROBERT C. MECREDY Vice President Nuclear Operations March 18, 2002 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Robert Clark Project Directorate I Washington, D.C. 20555
Subject:
Application for Amendment to Facility Operating License Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process (CLIIP)
Rochester Gas and Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Clark:
In accordance with the provisions of 10 CFR 50.90, Rochester Gas & Electric Corporation (RG&E) is submitting a request for an amendment to the Technical Specifications (TS) for Ginna Station.
The proposed amendment would modify TS requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3 as well as modify the associated TS Bases. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-358, Revision 6. The availability of this TS improvement was published in the Federal Register on September 28, 2001 (Federal Register Notice 66 FR 49714) as part of the consolidated line item improvement process (CLIIP).
Attachment 1 provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the existing TS Bases pages marked up to show the proposed change. Final TS Bases changes will be implemented pursuant to TS 5.5.13, Technical Specification Bases Control Program. Attachment 4 is provided for information only; however, RG&E will adopt these TS Bases changes upon implementation of the license amendment. This is the only commitment associated with this amendment request.
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It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.
Approval of this amendment application is requested at your earliest convenience. Once approved, this amendment will be implemented within 60 days.
to the In accordance with 10 CFR 50.91, a copy of this amendment application is being provided designated New York State official.
I declare under penalty of perjury under the laws of the United States of America that I am authorized by Rochester Gas and Electric Corporation to make this request and that the foregoing is true and correct.
If you should have any questions regarding this submittal, please contact Mr. Mark Flaherty, 585-771-3275.
Very truly yours, Executed on March 18, 2002 Robert C. Mecredy Vice President Nuclear Operations Group Attachments xc: Mr. Robert Clark (Mail Stop O-8-C2)
Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. William M. Flynn, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza Albany, NY 12223 ATTACHMENT 1 R.E. Ginna Nuclear Power Plant Description and Assessment
1.0 DESCRIPTION
The proposed amendment would modify Technical Specifications (TS) requirements for missed surveillances in Surveillance Requirements (SR) 3.0.3.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-358, Revision 6.
TSTF-358, Revision 6, incorporates the modifications made to TSTF-358, Revision 5, by Federal Register Notice 66 FR 32400, of June 14, 2001, and in response to public comments.
The availability of this TS improvement was published in the Federal Register on September 28, 2001 (Federal Register Notice 66 FR 49714) as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Rochester Gas and Electric Corporation (RG&E) has reviewed the proposed safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001, as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided with TSTF-358. RG&E has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Ginna Station and justify this amendment for the incorporation of the changes to the Ginna Station TS.
2.2 Optional Changes and Variations RG&E is not proposing any variations or deviations from the TS changes described in TSTF-358, Revision 6, or the NRC staffs model safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Determination RG&E has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. RG&E has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Ginna Station and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on September 28, 2001, for this TS improvement, plant-specific verifications were performed as follows:
RG&E has established TS Bases for SR 3.0.3 which state that use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances. The modification will also include changes to the Bases for SR 3.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that RG&E is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, RG&E has a Bases Control Program consistent with Section 5.5 of the STS.
4.0 ENVIRONMENTAL EVALUATION RG&E has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001 as part of the CLIIP. RG&E has concluded that the staff's findings presented in that evaluation are applicable to Ginna Station and the evaluation is hereby incorporated by reference for this application.
5.0 REFERENCES
5.1 Federal Register, Vol. 66, No. 115, "Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process," dated June 14, 2001.
5.2 Federal Register, Vol. 66, No. 189, "Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process, "dated September 28, 2001.
5.3 Industry/TSTF Standard Technical Specification Change Traveler TSTF-358, Revision 6, "Missed Surveillance Requirements."
ATTACHMENT 2 R.E. Ginna Nuclear Power Plant PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
SR Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) AND SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 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 SR, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. 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 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, 4 1_hours or up to the limit of the specified Frequency, whichever is&This delay period is permitted to allow performance of the Surveillance.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must t ere=d.
e=WeIn the Surveillance is performed within the delay period and the rbWhen Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
ArU.fk e 1Au.i4ev;.m~ I eJ r/ - -- KAY/$,v;~cc ~ey R.E. Ginna Nuclear Power Plant 3.0-4 Amendment 80
SR Applicability 3.0 SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.
Amendment(e R.E. Ginna Nuclear Power Plant 3.0-5
ATTACHMENT 3 R.E. Ginna Nuclear Power Plant PROPOSED TECHNICAL SPECIFICATION PAGES
SR Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) AND SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 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 SR, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. 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 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.
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. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
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.
R.E. Ginna Nuclear Power Plant 3.0-4 Amendment
SR Applicability 3.0 SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.
3.0-5 Amendment R.E. Ginna Nuclear Power Plant
ATTACHMENT 4 R.E. Ginna Nuclear Power Plant PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES (For Information Only)
SR Applicability B 3.0 As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with Refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified e Frequency, whichever is([sapplies from the point in time that it is S' discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of cofracewt he requiremnents.. When a S-urvilaneih a~x-j plant or operational intervals, situations, time is but upon specified discovered not to have been based not on C/Frequency when specified, SR 3.0.3 allows the full delay period of 24*
oburs to perform the Surveillance.
SR 3.0.3 also orovides a time limit for omoletion of Surveillances that becomeeapplicaqble as-a conseq uence o :DEcanges -imposed by Required Actions.
-o t' C AAA &ACe R.E. Ginna Nuclear Power Plant B 3.0-11 Revision 21
SR Applicability B 3.0 Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.
If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.
SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.
This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the plant. This Specification applies to changes in MODES or other specified conditions in the Applicability associated with plant shutdown as well as startup.
The provisions of this specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from a shutdown performed in response to the expected failure to comply with ACTIONS.
R.E. Ginna Nuclear Power Plant B 3.0-12 Revision 21
Insert 1 When a Surveillance with a Frequency based not on time intervals, but upon specified plant conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
Insert 2 While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed within the Corrective Action Program.