ML19325E428
| ML19325E428 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/27/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19325E426 | List: |
| References | |
| GL-89-14, NUDOCS 8911070061 | |
| Download: ML19325E428 (3) | |
Text
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SAFETY EVALUATION BY THE.0FFICE.0F NUCLEAR REACTOR. REGULATION q
is RELATED TO AMENDMENT NO.
140 TO FACILITY OPERATING LICENSE NO. NPF-3
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T0LEDO EDISON COMPANY b5 THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346
1.0 INTRODUCTION
t By letter dated August 23, 1989, Toledo Edison Company (the licensee) proposed 7
T changes to the Technical Specifications (TS) for Davis-Besse Nuclear Power Station. The proposed changes remove the provision of Specification 4.0.2.b 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.
3.0 EVALUATION Specification a.0.2 includes the arovision that allows a surveillance interval to be extended by 25 percent of t1e specified time interval. This extension provides flexibility for 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 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 o
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 18-month surveillance interval, with the provision 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 surveil-lances because the risk to safety is low in contrast to the alternative of a 8911070061 891027 PDR ADOCK 05000346 P
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' 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 1
. outage basis.
Extending surveillance intervals during plant operation can also result in a l
banefit to safety when a scheduled surveillance is due at a time that is not i
. 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.
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 Specificetion 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 3.25 limit on three consecutive surveillances with the following statement:
"4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowabh. extension not to exceed 25 percent of the specified surveillance interval."
l 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 it be used repeatedly merely as an cperational convenience to extend surveillance intervals beyond that specified.
The licensee has proposeo 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 change to the TS for Davis-Besse Nuclear Power Station, Unit 1, is acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the instal-lation or use of a facility component lecated within the restricted area as defined in 10 CFR Part 20 or a change to a surveillance requirement. The staff L
has' determined that the cmendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be I
l released offsite and that there is no significant increase in individual or l
cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards I
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 statcment or environmental assessment need be prepared in connection j
with the issuance of the amendment.
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s 5.0 CONCt.USION-The staff 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, 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 comon defense and security or to the health and safety of the public.
' Principal Contributors: Thomas V. Wambach Thomas G.' Dunning Dated:
October 27, 1989 9
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