ML17056B244

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Safety Evaluation Supporting Amend 121 to License DPR-63
ML17056B244
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 01/11/1991
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17056B242 List:
References
GL-89-14, NUDOCS 9101220163
Download: ML17056B244 (6)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.

121 TO FACILITY OPERATING LICENSE NO.

DPR-63 NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT NUCLEAR STATION UNIT NO.

1 DOCKET NO. 50-220 INTRODUCTION By letter dated February 26, 1990, as superseded October 26,

1990, and supplemented November 30, 1990, Niagara Mohawk Power Corporation, the
licensee, proposed changes to the Technical Specifications (TS) for Nine Mile Point Nuclear Station, Unit No.

1 (NMP-1).

The proposed changes would remove the provision of Definition 1. 15 that limits the combined time interval for three consecutive surveillances to less than 3.25 times the specified interval.

This change would also revise and relocate to a new section, 4.0.1 Surveillance Intervals, the maximum allowable extension to ly tl dl 5

515-Definition.

The Bases applicable to the new Section 4.0.1 would also be added.

Guidance on this proposed change to TS was provided to all power reactor licensees and applicants by Generic Letter 89-14 dated August 21, 1989.

EVALUATION Specification 1.15 includes the provision that allows a surveillance interval to be extended by 25 percent of the specified time interval.

This extension provides flexibilityfor scheduling the performance of surveillances and to permit consideration of plant operating conditions that may not be suitable for conducting a surveillance at the specified time intervals.

Such operating conditions include transient plant operation or ongoing surveillance or maintenance activities.

Specification

1. 15 further limits the allowance for extending surveillance intervals by requiring that the combined time interval for any three consecutive surveillances not exceed 3.25 times the specified time interval.

The purpose of this provision is to assure that surveillances are not extended repeatedly as an operational convenience to provide an overall increase in the surveillance interval.

Experience has shown that the 24 month surveillance interval, with the provision to extend it by 25 percent, is usually sufficient to accomodate normal variations in the length of a fuel cycle.

However, the NRC staff has routinely granted requests for one-time exceptions to the 3.25 limit on 9iOi220ih3 9iOiii PDR ADOCK 05000220 P

PDR

lf extending refueling surveillances because the risk. to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances.

Therefore, the 3.25 limitation on extending surveillances has not been a practical limit on the use of the 25-percent allowance for extending surveillances that are performed on a refueling outage basis.

Extending surveillance intervals during plant operation can also result in a benefit to safety when a scheduled surveillance is due at a time that is not suitable for conducting the surveillance.

This may occur when transient plant operating conditions exist or when, safety systems are out-of-service for maintenance or other surveillance activities.

I'n such

cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit derived by limiting the use of the 25-percent allowance to extend a surveillance.

Furthermore, there is the administrative burden associated with tracking the use of the 25-percent allowance to ensure compliance with the 3.25 limit.

In view of these findings, the staff concluded that the 3.25 limit should be removed for all surveillances because its removal will have an overall positive effect on safety.

The guidance provided in Generic Letter 89-14 included the following change to this specification and removes the 3.25 limit on three consecutive 'survei llances with the following statement which will be relocated, for consistency, in a newly created section, 4.0.1, Surveillance Intervals:

"Each Surveillance Requirement shall be performed within the specifieo surveillance interval with a maximum allowable extension uot to exceed 25 percent of the specified surveillance interval."

Also, the Bases applicable to Specification 4.0.1 will be added, These Bases note that it is not the intent of the allowance for extending st rveiilancL intervals that it be used repeatedly merely as an operational conver.i~nce to extend surveillance intervals beyond that specified.

In addition, for consistency with technical specifications nomenclature, the section entitled, "Operability Requirement" on page 25 will be given the number 3.0.1, and a

new heading, 4.0, Surveillance Re uirements, will contain, the newly created Section 4.0.

an assoc>a e

ases.

A new page, 25a, will be added due to space limitations on page 25.

The licensee, by letter dated November 30, 1990, provided supplemental information.

This supplemental submittal did not affect the proposed TS change noticed in the Federal Re ister and did not affect the staff's proposed determination Via~no ssgns

~cant hazards would result from these changes.

The supplemental submittal, included the following corrections per staff request:

Section 3.0.2 was renumbered as 4.0 and a heading, 4.0. 1, Surveillance Intervals, was added.

0 ENVIRONMENTAL CONSIDERATION This amendment involves a change in a requirement with respect to the installation or use of the facility.components located within the restricted areas as defined in 10 CFR Part 20.

The staff has determined that this amendment involves no, significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

CONCLUSION We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated:

January 11, 1991 PRINCIPAL CONTRIBUTOR:

T. Dunning