ML17328A371

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Safety Evaluation Supporting Amends 143 & 130 to Licenses DPR-58 & DPR-74,respectively
ML17328A371
Person / Time
Site: Cook  
Issue date: 08/03/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17328A370 List:
References
NUDOCS 9008160045
Download: ML17328A371 (5)


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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 N0.143 TO FACILITY OPERATING LICENSE NO. DPR-58 AND AMENDMENT NO.g30 TO FACILITY OPERATING LICENSE NO. DPR-74 INDIANA MICHIGAN POWER COMPANY OONALO C.

COOK NUCLEAR PLANT UNITS NOS. I ANO 2 DOCKETS NOS. 50-315 AND 50-316

1.0 INTRODUCTION

By letter dated February 7, 1990, Indiana Michigan Power Company (the licensee) proposed changes to the Technical Specifications (TS) for the D.

C.

Cook Nuclear Plant, Unit Nos. I and 2.

The proposed change removes the provision of Specification 4.0.2 that limits the combined time interval for three consecutive surveillances to less than 3.25 times the specified interval.

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.

2.0 EVALUATION Specification 4.0.2 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 corIducting a surveillance at the specified timIe interval.

Such operating conditions include transient plant operation or ongoing surveillance or main-tenance 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 assure that survei llances are not extended repeatedly as an operational convenience to provide an overall increase in the surveillance interval.

A Experience has shown that the 18-month surveillance interval, with the provi-sion to extend it by 25 percent, 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 of safety is low in contrast to 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 percent allowance for extending surveillances that are performed on a refueling outage basis.

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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 main-tenance or other surveillance activities.

In 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 Specification 4.0.2 should be changed to remove the 3.25 limit for all survei llances 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 surveillance with the following statement:

"4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent 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 extending surveillance intervals that is to be used repeatedly merely as an operational convenience to extend surveillance intervals beyond that 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 above changes to the TS for'the Donald C.

Cook Nuclear Plant Units 1 and 2 are acceptable.

3. 0 EHVI ROHl'lEHTAL CONSIDERATION These amendments involve changes in 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 changes in a surveillance requirement.

he have 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 these amendments involve no significant hazards consideration and there has been no public comment on such finding.

Accordingly, these amendments meet 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 these amendments.

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that (1) there is reasorable 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.

Date:

August 3, 1990 Principal Contributor:

Thomas G. Dunning, OTSB/DOEA

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