ML17056A721

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Requests That 900226 Application for Amend to License DPR-63 Re Removal of 3.25 Limit on Extending Surveillance Intervals Be Revised to Address Bases Section,Per Generic Ltr 89-14.Suggested Format Listed
ML17056A721
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 03/27/1990
From: Martin R
Office of Nuclear Reactor Regulation
To: Burkhardt L
NIAGARA MOHAWK POWER CORP.
References
GL-89-14, TAC-76073, NUDOCS 9004060505
Download: ML17056A721 (8)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 March 27, 1990 Docket No. 50-220 Mr. Lawrence Burkhardt, III Executive Vice President, Nuclear Operations Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212

Dear Mr. Burkhardt:

Subject:

A LINE ITEM TECHNICAL SPECIFICATION IMPROVEMENT -

REMOVAL OF 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS (GL 89-14; TAC NO. 76073)

Generic Letter 89-14, issued on August 21, 1989, encouraged licensees to propose changes to plant Technical Specifications that limited the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified surveillance interval.

This was based on the staff's conclusion that removal of the 3.25 limit results in a greater benefit to safety than limiting the use of the 25 percent allowance to extend surveillance intervals.

The guidance of the generic letter was based on the Standard Technical Specification (STS) format.

On February 26, 1990 the Niagara Mohawk Power Corporation submitted an application to amend the Nine Mile Point Unit 1 technical specifications in response to this generic letter.

We have performed a review of the amendment application and find it to be unacceptable since it incorporates only part of the guidance of the generic letter.

As noted in the generic letter, since the application deviates from it, a more protracted review process is necessary.

Specifically, the generic letter indicated that the TS on surveillance requirement intervals, identified as item 4.0.2 in the STS, be modified to delete the 3.25 limit and that associated changes should be made to the BASES.

The NMPC amendment application of February 26, 1990 proposed the first change but failed to include any modification of the BASES.

Nor is there any justification provided in the application of this deviation from the guidance of the generic letter.

We require that the BASES for the proposed revision to the TS be addressed prior to our further consideration of the application.

In consideration of the custom format of the NMP-1 TS we suggest that an acceptable approach to this would be as follows:

1.

The present TS 1.15 consists of a definition (first sentence) and a limit (second and third sentences).

The limit portion should be moved to a

newly created TS 3.0.1 on the currently numbered page 25.

It would then be consistent with the STS with respect to location of limits in the TS.

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2.

The newly created TS 3.0.1 should be followed by its BASES for which the guidance in the generic letter will suffice.

3.

These changes will likely require moving TS 3.1.0 to a

new page 25a.

Ne request that the amendment application be revised with respect to these issues and resubmitted within sixty days of receipt of this letter.

In the event that a revised application has not been submitted within a sixty day period we will review this issue with your staff and may, at that time, conclude that the amendment application is not suitable for further processing by the staff and may, accordingly, deny it.

The reporting and/or recordkeeping reauirements of this letter affect fewer than ten respondents; therefore OHB clearance is not required under PL 96-511.

If you have further questions please contact us.

S incere ly, cc:

See next page Robert E. Hartin, Senior Project Hanager Project Directorate I-1 Division of Reactor Projects - IVIII Office of Nuclear Reactor Regulation

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Mr,. L. Burkhardt III

.N-'agara Mohawk Power Co(poration Nine Point Nuclear Station, Unit No.

1 CC:

Mr. Troy B. Conner, Jr., Esquire Conner 5 Wetterhahn Suite 1050 1747 Pennsylvania

Avenue, N.

W.

Washington, D. C.

20006 Mr. Frank R. Church, Supervisor Town of Scriba R.

D. 02

Oswego, New York 13126 Mr. James L. Willis Genera 1 Supt.-Nuclear Generation Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Post Office Box 32
Lycoming, New York 13093 Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 126
Lycoming, New York 13093 Mr. Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West
Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Coomission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms. Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor
Albany, New York 12223 Mr. Kim Dahlberg Unit 1 Station, Superi,ntendent Nine Mile Point Nuclear Station Post Office,Box 32
Lycoming, New York 13093

'r.

Peter E. Francisco',

Licensing Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 Charlie Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Mr. Paul D. Eddy State of New York Department of Public Service Power Division,,System Operations 3 Empire State Plaza
Albany, New York 12223

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III 2.

The newly created TS 3.0.1 should be followed by its BASES for which the guidance in the generic letter will suffice.

3.

These changes will likely require moving TS 3.1.0 to a new page 25a.

He request that the amendment application be revised with respect to these issues and resubmitted within sixty days of receipt of this letter.

In the event that a revised application has not been submitted within a sixty day period we will review this issue with your staff and may, at that time, conclude that the amendment application is not suitable for further processing by the staff and may, accordingly, deny it.

The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore OMB clearance is not required under PL 96-511.

If you have further questions please contact us.

S incere ly, Original signed by cc:

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