ML17156A511
| ML17156A511 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/04/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17156A512 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 8804150141 | |
| Download: ML17156A511 (8) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR RFACTOR REGULATION SUPPORTING AMENDMENT NO. 78 TO FACILITY OPERATING LICENSE NO.
NPF-14 AND AMENDMENT NO. 43 TO FACILITY OPERATING LICENSE NO.
NPF-22 PFNNSYLVANIA POWER 5 LIGHT COMPANY ALLFGHENY ELECTRIC COOPERATIVE, INC.
DOCKET NOS.
50-387 AND 50-388 SUS UEHANNA STEAM ELECTRIC STATION, UNITS 1
AND 2
- 1. 0 INTRODUCTION By letter dated October 7, 1987, Pennsylvania Power 8 Light Company (licensee) requested amendments to Facility Operating License Nos.
NPF-14 and NPF-22 for the Susquehanna Steam Electric Station (SSES}, Units I and 2.
The proposed amendments would change the SSES Units 1 and 2 Technical Specifications based on the recommendations provided by the staff in Generic Letter 87-09 related to applicability of limiting conditions for operation (LCO) and surveillance requirements of Technical Specification Sections 3.0 and 4.0.
Specifically, the licensee has requested following revisions to Technical Specifications 3.0.4, 4.0.3, and 4.0.4.
3.0.4 is revised to define when its provisions apply (i.e.
when the affected action statements permit continued operation for an unlimited period of timel instead of defining when the provisions of Section 3.0.4 do not apply.
r 4.0.3 is revised to incorporate a 24-hour delay in implementing action requirements due to a missed surveillance when the action requirements provide a
r estnration time that is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
4.0.4 is revised to clarify that "This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements."
- 2. 0 EVALUATION The proposed changes to the SSES Technical Specifications 3.0.4, 4.0.3, and 4.0.4 are consistent with the related staf positions outlined in the Generic Letter 87-09 dated Iune 4, 1987.
The changes proposed by the licensee are compared with staff positions as follows.
TecIInical S ecification 3.0.4 In the Generic Letter 87-09 the staff took the followinq position related to specification 3.0.4 changes which will prevent inconsistent application of sections 3.0.4.
BEIP4150141 880003EI7 PDR ADOC}< 0500 Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safety for continued operation.
For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements.
This is consistent with NRC's regulatory requirements for an LCO.
The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements establish a specified time interval in which the LCO must be met or a shutdown of the facility would be required.
However, nothing in this staff position should be interpreted as endorsing or ~ncouraqing a plant startuo with inoperable equipment.
The staff believes that good practice should 'dictate that the plant startup should normally be initiated only when all required equinment is operable and that startup with inoperable equipment must be the exception rather than the rule.
As a result of the above staff position, the licensee s could chanqe the section 3.0.4 to define the conditions under which its requirements apply.
The staff proposed the following replacement for section 3.0.4.
"Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met wi thin a specified time interval.
Entry into an OPERAT'0"iAL MODE or specified condition may he made in accordance with ACTION reauirements when conformance to them permits continued operation of the facility for an unlimited period of time."
The proposed change to section 3.0.4 conforms to the above staff proposal and is therefore acceptable.
Technical S ecification 4.0.3 In the heneric Letter 87-09, the staff took the following position related to specification 4.0.3.
It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed.
The ooposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are operable.
Mhen a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of the required surveillance.
Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performina a missed surveillance be~ore shutdown requirements may apply, the Technical Specifications should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance.
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I rt This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as the safety significance of the delay in completion of the surveillance.
After reviewing possible limits, the staff has concluded
- that, based on these considerations, P4-hours would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements applv.
The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the ~isks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.
Although a missed surveillance would generall,y be completed in less time than this 24-hour limit allows, special circumstances may require additional time to ensure that the surveillance can be conducted in a safe manner.
The time limits of Action Requirements for survei llances should start when it is identified that Surveillance Requirements have not been performed, except when the 24-hour delay is allowed in the implementation of the Action Requirements.
Where the 24-hour time limit is allowed, the time limits of the Action Requirements are applicable either at the end of the 24-hour limit if the surveillance has not been completed or at the time the surveillance is performed if the system nr component is found to be inoperable.
Several issues need to be clarified regarding the additio~al 24-hour time limit.
First, this limit does not waive compliance with Specification 4.0.3.
Under Specification 4.0.3, the failure to perform a Surveillance Requirement will continue to constitute noncompliance with the Operability Requirements of an LCO and to bring into play the applicable Action Requirements.
- Second, Specifications 3.0.2 and 4.0.3 should not be misinterpreted.
Specification 3.0.2 notes that a
TS is being complied with when the Action Requirements are met within the specified time intervals.
Although Specification 4.0.2 provides an allowance for extending the surveillance interval and allows for the completion of the surveillance within this time interval without violation of this Specification, under Specification 4.0.3 nonperformance of a Surveillance Requirement, within the allowed surveillance interval defined by Specification 4.0.2, constitutes a violation of the Operability Requirements of an LCO, as defined by Specification 4.0.3, and is subject tn enforcement action.
Third, even though an additional 24-hour time limit may apply for missed survei llances, another consideration is the possibility that plant conditions may Dreclude the performance of the specified requirements.
The provision of a 24-hour delay in the application of the Action Requirements for the completion of a missed surveillance would provide time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of current plant conditions.
If a surveillance can be performed only when the plant is shut down, there are only two options available to licensees when a missed surveillance is discovered during power operation and continued operation is not allowed under the Action Requirements.
The first is to shut down the plant and perform the required surveillance.
The other option is to seek relief from the Surveillance Requirement.
As a result of the above staff position, the Specification 4.0.3 could be revised as follows to clarify when a missed surveillance constitutos a
violation of the Operability Requirements of an LCO and to clari<y the applicability of the Action Requirements and the time during which the limits apply:
P "Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncomoliance with the OPERABILITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION reouirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.
The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit th~ completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
Specification 4.0.3 previousl,r included the statement that exceptions to it ar~ stated in individual specifications.
This statement is deleted because Specification 4.0.3 is always applicable, i.e., the implied exceptions for individual specifications do not exist.
The licensee has proposed a revised section 4.0.3 which is identical'o the above staff proposal.
The proposed revision to specification 4.0.3 is therefore acceptable.
Technical Specification 4.0.4 In the Generic Letter 87-09, the staff took the following position relative tn specification 4.0.4.
The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with Action Requirements.
It is not the intent nf Specification 4.0.4 to prevent passage through or to operational modes tp comply with Action Requirements and it should not apply when mode change's are imposed by Action Requirements.
Accordingly, Specification 4.0.4 should be modified to note that its provisions shall not prevent passage through or to nperational modes as required to comply with Action Requirements.
A similar provision is included in Specification 3.0.4.
The following will clarify Specification 4.0.4 for mode changes as a
consequence of Action Requirements:
"This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION Requirements."
The licensee has proposed Specification 4.0.4 change which is identical to the above staff proposal.
The proposed change is therefore acceptable.
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3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve changes to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and chanqes to the surveillance requirements.
The staff has determined that these amendments involve 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 previousl.y issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding.
Accordinqly, these amendments meet the eligibility criteria for categorical exclusion set <orth in 10 CFR 51.22{c)(9).
Pursuant to 10 CFR 51.22(b} no environmental=impact statement nor environmental assessment need be prepared in connection with the issuance of these amendments.
- 4. 0 CONCLUSION The Commission made a proposed determination that these amendments involve no significant hazards consideration which was published in the Federal Re ister
{52 FR 49230) on December 30, 1987 and conso1ted with the Sta~te o
Pennsy vania.
No public comments were received, and the State of Pennsylvania did not have any comments.
The staff has concluded, based on the considerations discussed above, that:
(I) there is reasonable assurance that the health and safety of the public wi 11 not be endanqered by operation in the proposed
- manner, and (2} such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributor:
H. Thadani Dated: April 4> l988
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