ML19325E879
| ML19325E879 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 11/03/1989 |
| From: | Paulson W Office of Nuclear Reactor Regulation |
| To: | Deddens J GULF STATES UTILITIES CO. |
| References | |
| GL-87-09, GL-87-9, TAC-69579, NUDOCS 8911090280 | |
| Download: ML19325E879 (4) | |
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November 3,1989 Docket No. 50-458' Gulf States Utilities ATTN: Mr. James C. Deddens SeniorVicePresident(RBNG)
Post Office Box 220 St. Francisville, Louisiana 70775
Dear Mr. Deddens:
SUBJECT:
PROPOSED H0DIFICATION TO TECHNICAL SPECTelCATION 4.0.3 IN RESPONSE.T0 GENERIC LETTER 67-09 (Tid, NO. 69579)
By letter dated September 30, 1908, Gulf States Utilities submitted an application for an amendment to facility Operatin9 License NPF-47 for River Bend Station.
The proposed amendment would medity Technical Specifications (TSs) 3.0.4, 4.0.3, an 4.0.4 in response to Generic Letter 87-09 dated May 4,1987.
Enclosure' 5 to Generic Letter 87-09 provides revised Bases for all specifications-in Sections'3.0 and 4.0 of the Boiling Water Reactor Standard Technical Specifica-tions. The Basis for Specification 4.0.3 states in part:
ThisspecificationaisoclarifiesthattheACTIONrequirementsare applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the tine limits of the ACTION requirements apply fron. the point in time it is identi-fied that'a surveillance has not been performed and not at the time that.the allowed surveillance interval was exceeded. Completion of the Suru111ance Requirement within the allowable outage tin:e limits of the ACTION requirements restores compliance with the requirements of Specifi-cation 4.0.3.
However, this does not negate the fact that the failure to have performed the surveillarce within the allowed surveillance interval, defined by the provisions of Specificatinn 4.0.2, was a violation of the OPERABILITY requirements of a Limiting Condition for Operation that is subject to enforcement action. Further, the failure to perform a surveillance within the provisions of Specification 4.0.2 is a violation therefore, a reportable
~ofaTechnicalSpecificationrequirementandis(2)(1)(B)becauseitisa event under the requirements of 10 CFR 50.73(a) condition prohibited by the plant's Technical Specifications.
'CSU's. submittal proposed revising the above portion of the Basis for the TS as follows:
' This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillarce interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillerce interval was exceeded. Completion of the requirerents restores compliance with the i
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f Mr. Jarr.cs C. Deddens requirements of Specification 4.0.3.
The failure te have perforrad the suryciller.ce within the allowed surveillerte interval, defined by the provisions of Specification 4.0.2, constitutes a failure to fueet the OPERABILITY requirements for a Limiting Condition for Operation ar.d any reports required by 10 CFR 50.73 shall be determined based on the length of tiene the surveillance interval has been exceeded, and the corresponding Lir.liting Conditions for Operation ACT10ll time requirements, es discussed ir, NUREG-1022, Supplement 1.
At the request of the NRC staff, GSU submitted a letter dated July 17, 1989 that provided further explanation for this proposed revision to the Bases.
Whereas tht staff's position states that reissing a surveillerce interval within the arovisions of TS 4.0.2.is a violation of the TS and is reportable under 10 CPR 50.73, the CSU wording allcys a longer period, beyond the expirttion cf the survtillar.cc interval, before a report pursuant to 10 CFR E0.73 is required.
The hF,C staff hes reviewed the Septerter 30, 1988 and July 17, 1989 subtrittals,
NUREG-1072, Supplertent 1, and has had the berefit of several conversations with GSU persensiti regarding this scatter.
Based on its review, the staff concludes that GSU's positicn is not accepteble.
Reports on ruissed survcillances should be reported ts stated in Enclosure 5 to Generic Letter 87-09 to provide the !!EC with ii.forr.ation to assess the trer.d of riissed surveillances.
1 AcccrdinD y, the staff will r.ct act on your proposed Technical Specificatien 4.0.3 with the associated Pases as curier,tly worded.
Sincerely, o
{I5 k O,f.O dqv Walter A. Paulsen, Project lianager Project Directcrete IV l
Divisicr cf Reactor Projects - 111, IV, V and Special Projects Office of Nuclear Reactor Regulation cc: See next page l.
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November 3,1989
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... t Mr. James C. Deddens !
requirements'of Specification 4.0.3.
The failure to have performed the surveillar.ce within the allowed surveillerce interval, defined by the provisions of Specification 4.0.2, constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation end any reports required by 10 CFR 50.73 shall be determined based on the length of time the surveillence interval has been exceeded, and the ccrresponding:
r4 t Limiting Conditions for Operation ACTION time requirements, as discussed l
l ir. NUREG-1022 Supplement 1.
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At the n quest of the NRC staff, GSU submitted a letter dated July 17, 1989 t
3
' that.provided further explanation for this proposed revision to the Bases.'
. '1 Whereas the staff's position states that missing a surveillance interval within
? l' theN rovisions of TS 4.0.2'is a violation of the TS and is reportable"under Mi 10 CPR~S0.73, the GSU wording allows a longer period, beyond the expiration of 4
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<the{ surveillance interval, before a report pursuant to 10 CFR 50.73 is' required.
?
,,;1 wt The'NRC staff has reviewed the Septeo.ber 30, 1988 and July 17, 1089 submittals, C
L, NUREG-1022, Supplement 1, and has had the benefit of several conversations with
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, GSU personnel regarding this matter. Based on its review, the staff concludes that GSU's position is not acceptabic.
Reports on missed surveillances should be reported es stated in Enclosure 5 to Generic Letter 87 09 to provide the NRC.
with'.information to assess the trend of missed surveillances.
i Accordingly, the staff will oct act on your proposed Technical Specification 4.0.3 with the associated Cases as currently worded.
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Sincerely, l
/s/
Walter A. Paulson, Project Manager Project Directorate IV Division of Reactor Projects - Ill, IV, V and Special Projects Office of Nuclear Reactor Regulation ec: See next page o
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Document Name: RB LTR/GL 8709
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Mr. James C. Deddens j
Gulf States Utilities Company River Bend Nuclear Plant cc Troy B. Conner, Jr., Esq.
Mr. J. E. Booker Conner and Wetterhahn Manager-River Bend.0versight 1747 Pennsylvania Avenue, NW P. O. Box 2951 Washington, D.C.
20006 Beaumont TX 77704 Mr. Les England Mr. William H. Spell Administrator Director - Nuclear Licensing NuclearEnergyDivisIon Gulf States Utilities Company Office of Environmental Affairs i
P. O. Box 220 P. O. Box 14690 St. Francisv111e, LA 70775 Baton Rouge, Louisiana 70898 e
Richard M. Troy, Jr., Esq.
Assister:t Attorney General in Charge Mr. J. David McNeill, III State of Louisiana Department of Justice William G. Davis, Esq.
234 Loyola Avenue Departrient of Justice New Orleans, Louisiana 70112 Attorney General's Office P. O. Box 94095 Pesident, Inspector Baton Rouge, Louisiana 70804-9095 P. 0.. Box'1051 St. Francisv111e Louisiana 70775 H. Anne P1ettinger 3456 Villa Rose Drive President of West Feliciana Baton Rouge, Louisiana 70806 Police Jury P. O. Box 1921 St. Francisv111e, Louisiana 70775 Philip G. Harris Cajun Electric Power Coop. Inc.
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Regional Administrator, Region IV 10719 Airline Highway
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U.S. Nuclear Regulatory Comission P. O. Box 15540 Office of Executive Director Baton Rouge, LA 70895 for Operations 1
611 PJan Plaza Drive, Suite 1000 Arlington, Texas 76011 1.
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