ML17164A621

Safety Evaluation Supporting Amends 144 & 113 to Licenses NPF-14 & NPF-22,respectively

ML17164A621
Person / Time
Site:	Susquehanna
Issue date:	02/28/1995
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17164A620	List: ML17164A621
References
NUDOCS 9503090365
Download: ML17164A621 (4)

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By letter dated June 23, 1994, the Pennsylvania Power and Light Company (the licensee) submitted a request for changes to the Susquehanna Steam Electric Station (SSES),

Units 1 and 2, Technical Specifications (TS).

The requested changes would revise Technical Specification 4.0.5, which provides the requirements for inservice inspection and testing of ASHE Code components, to conform to Standard Technical Specifications (STS, i.e.

NUREG-1433).

2.0 Qg VARDON TS 4.0.5 contains surveillance requirements for inservice inspection (ISI) and testing of the American Society of Hechanical Engineers Boiler and Pressure Vessel Code (ASHE Code) components.

Presently, TS 4.0.5.a states that specific written relief from the COInIIission is required for relief requests.

This specification could be interpreted to be more restrictive than the regulations in 10 CFR 50.55a.

In order to avoid any misinterpretations, the licensee proposes to revise TS 4.0.5 for both units to conform to the Standard Technical Specifications (NUREG-1433).

The following is a description of the proposed changes:

(1)

Revise item a of TS 4.0.5 by deleting "(g), except where specific written relief has been granted by the Coaeission pursuant to 10 CFR 50, Section 50.55 a(g)(6)(i)."

(2)

Revise item b of TS 4.0.5 to read "......Pressure Vessel Code and applicable Addenda are as follows" from the present wording of

"......Pressure Vessel Code and applicable addenda shall be applicable as follows in these Technical Specifications".

(3)

Add "Biennially or every 2 years" and "At least once per 731 days" to item b in the frequency table.

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(4)

Replace item d of TS 4.0.5 "Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements,"

with the statement "The provisions of Specification 4.0.3 are applicable to inservice testing activities."

(5)

Revise Bases

Section, page 8 3/4 0-6, for Specification 4.0.5, by deleting the statement, "these requirements apply except when relief has been provided in writing by the Commission."

(6)

Unit 2 only, delete the ** footnote on page 3/4 0-2 which is no longer applicable to Unit 2.

The proposed change (1) conforms to STS section 5.7.2.12.a, proposed changes (2) and (3) conform to STS section 5.7.2.12.b, and proposed change (4) conforms to STS section 5.7.2. 12.d.

The proposed change (5) removes the requirement to have NRC approval of reliefs from the ASIDE code of record and is consistent with change (1) and the proposed change (6) is an administrative change only.

The Standard Technical Specifications (NUREG-1433) reflect the staff's position that the licensee must establish and implement the program in accordance with 10 CFR 50.55a, which permits a licensee to inform the staff of the ASIDE Code requirements which are impractical and to request relief up to 12 months after the beginning of the updated interval.

If later in the interval, the licensee finds a specific need for relief, the request should be submitted for NRC approval after identification of the impractical requirement.

For 120-month updated programs, relief requests should be submitted prior to the interval start date to allow a period for NRC review 12 months after the interval start date (i.e.,

submit the updated program 3 to 6 months prior to the start date, or earlier).

Upon determining an impractical requirement and not including that requirement in the revised inservice test or inspection

program, the licensee must follow the requirements of 10 CFR 50.55a(f)(5)(iv) or (g)(5)(iv), as applicable.

The change to the specification does not allow the licensee to implement alternative testing under 10 CFR 50.55a, paragraphs (a)(3)(i) and (a)(3)(ii), until the NRC has determined that such alternatives are authorized, and has issued a safety evaluation to the licensee.

However, this TS change will enable licensees to avoid situations where compliance with the current TS cannot be achieved, for the period between preparation and submittal of a relief request as part of a revised inservice test or inspection program during the first 12 months of the program, and issuance of the NRC's safety evaluation and granting of relief.

This situation could occur at the beginning of a new interval.

Following implementation of the TS change, when a Code requirement is practical, but an alternate method is requested, approval from the NRC is required before implementing the alternative method of testing (1) proposed to achieve levels of quality and safety equivalent to those of the Code method or (2) proposed to avoid an undue hardship without yielding a compensating increase in the level of quality and safety.

Additionally, for inservice

testing, the licensee may use the guidance in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," for alternatives 'that the staff has determined are acceptable for implementation.

The staff agrees that the proposed changes are administrative in nature.

The proposed revision to TS 4.0.5 eliminates the possibility of misinterpretation of the ASME Code requirements.

It is permissible for a utility to submit relief requests that are based on impracticality to the NRC within 1 year of the beginning of the updated interval and to implement these requests prior to NRC review and approval.

Further, the NRC will continue to provide acceptance of the relief requests in writing.

Therefore, the staff concludes that the proposed revision to TS 4.0.5 for

SSES, Units 1 and 2 to reflect the Standard TS section 5.7.2.12 in order to avoid any misinterpretations is acceptable.

The staff finds the change to the Bases section and the administrative deletion of the footnote on page 3/4 0-2 also to be acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change surveillance requirements.

The NRC 'staff has determined that the 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 previously issued a

proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (59 FR 39595).

Accordingly, the amendments meet 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 the amendments.

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The Commission has 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, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

T. Liu P.

Campbell Date: February 28, 1995

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