ML17285B226

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Safety Evaluation Supporting Amend 82 to License NPF-21
ML17285B226
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/26/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17285B225 List:
References
GL-89-14, NUDOCS 9005010271
Download: ML17285B226 (5)


Text

0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPOPTING AMENDMENT N0.82 TO FACILITY OPERATING LICENSE NO. NPF-21 WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO.

2 DOCKET NO. 50-397

1.0 INTRODUCTION

2.0 By letter dated October=27, 1989, the Washington Public Power Supply System proposed changes to the Technical Specifications for Nuclear Project No. 2.

The proposed change removes the provision of specification 4.0.2 that limits the combined time interval for three consecutive surveil-lances to less than 3.25 times the specified interval.

Guidance on this proposed change to technical specifications was provided to all power reactor licensees and applicants by Generic Letter 89-14, "Removal of the 3.25 Limit on Extending Surveillance Intervals," dated August 21, 1989.

EVALUATION Specification 4.0.2 includes the provision that allows a surveillance interval to be extended by 25 per cent of the specified time interval.

The extension provides flexibilityfor scheduling the performance of survei llances and to permit consideration of plant operating conditions that may not be suitable for conducting a surveillance at the specified time interval.

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

Specification 4.0.2 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 ensure that surveillances are not extended repeatedly as an operational convenience to provide an overall increase in the surveillance interval.

Experience has shown that the 18 month surveillance interval, with the provision to extend it by 25 per cent, is usually sufficient to accommodate 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 extending refueling surveillances because the risk to safety is low as compared with the alternative of a forced shutdown to perform these survei llances.

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

Extending surveillance intervals during plant operation can also result in a benefit to safetv when a scheduled surveillance is due at a time 90050i027i 900426 PDR ADOCK 05000397 P

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that is not suitable for conducting the surveillance.

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

In such cases, the benefit to safety of extending a surveillance interval would exceed any safety benefit to be derived by limiting the use of the 25 per cent allowance to extend a surveillance.

Further, there is an administrative burden associated with tracking the use of the 25 per cent allowance to ensure compliance with the 3.25 limit.

In view of these findings, the staff concluded that specification 4.0.2 should be changed to remove the 3.25 limit 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 the 3.25 limit on three consecutive surveil-lances with the following statement:

"4.02 Each surveillance requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 per cent of the specified surveillance interval."

In addition the bases of this specification were updated to reflect this change and noted that it is not the intent of the allowance for exceeding surveillance intervals that it be used repeatedly merely as an operational convenience to extend surveillance intervals beyond those specified.

The licensee has proposed changes to specification 4.0.2 that are consistent with the guidance provided in Generic Letter 89-14, as noted above.

On the basis of its review of this matter, the staff finds that the proposed change to the technical specifications for WNP-2 is acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in a requirement with respect to survei 1-lance of facility components located within the restricted area 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 signif-icant 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.

4.0 CONTACT WITH STATE OFFICIAL The Commission made a proposed determination that the amendment involves no significant hazards consideration (54 FR 53216, December 27, 1989) and consulted with the State of Washington.

No public comments were received, and by letter dated March 20, 1990 the State of Washington advised that they have no comment.

5. 0 CONCLUSION Me 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 regula-tions and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

Thomas G. Dunning, OTSB/DOEA Dated:

April 26, 1990

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