ML19327B446

Application for Amends to Licenses DPR-51 & NPF-6,removing 3.25 Limit on Surveillance Interval Extension,Per Generic Ltr 89-14

ML19327B446
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/19/1989
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19327B447	List: ML19327B446 ML19327B448
References
0CAN108901, CAN108901, GL-89-14, NUDOCS 8910310211
Download: ML19327B446 (7)

Text

'

3 Attennes g!- ,s Power & Light Company  ;

n. *L""""* / 4?6 West capitol '

P o Bon I.61 *

[" '*

Little Rock Arunsat 72203 '

L Tel 501377 3626 T G. Comptiet NI" i

[r October 19, 1989 L SCAN 198981 U. S. Nuclear Regulatory Commission  !

Document Control Desk E Washington, DC 20555 l

Subject:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368  !

License Nos. DPR-51 and NPF-6 i Technical Specification Amendment Request per GL 89 l Removal of 3.25 Limit on Surveillance Interval Extension j Gentlemen: l i

Generic Letter 89-14, dated August 21, 198? (9CNA888922), recommended that  !

licensees propose changes to remove the technical specification that limits [

I the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified interval. As described in GL 89-14,  !

the NRC staff concluded that the removal of the 3.25 limit results in a  !

greater benefit to safety than limiting the use of the 25 percent allowance  ;

to extend surveillance intervals. Attached are proposed c.hanges to the j

. appropriate ANO-1 and 2 Technical Specifications, in conformance with the guidance enclosed with GL 89-14. The changes proposed for ANO-2 closely '!

resemble the Standard Technical Specification (STS) suggested language. It i i should be noted that ANO-1 has custom technical specifications; therefore. [

the specific proposed changes are somewhat different, although they meet the  :

intent of the GL 89-14 guidance. An additional enange is proposed to the t associated ANO-1 specification to remove the 25 percent allowance on ,

reducing surveillance intervals. This restriction is not included in the '

STS and provides no safety benefit, and its removal will provide additional  !

operational flexibility.

AP&L has evaluated the proposed changes using the criteria in 10CFR50.92(c) l L and determined that the proposed changes involve no significant hazards  !

lF consideration. A copy of this determination is attached. It should be  !

l noted that our evaluation is based primarily on the NRC staff's prior safety (

l evaluation of the recommended changes, as discussed in GL 89-14. This was confirmed as adequate during discussions v<ith the ANO-2 NRC Project Manager. '

O(

8910310211 891019 '

ils PDR ADOCK 05000313 \

P PDC An Entergy Company  !

N

l. U.S. WRC 3 l Page 2.

i October 19, 1989 l l l l-The circumstances of this amendment request are neither exigent nor emergency; however, AP&L requests prompt NRC processing and approval, as the proposed changes will provide scheduling benefits in the ongoing ANO-2 refueling outage, which began September 25, 1989, and the upcoming ANO-1 ,

mid-cycle maintenance outage scheduled for later this year. AP&L therefore requests that the preposed changes become effective upon issuance, i

i Very truly yours.

x.rY /

T. G. Campb 11 TGC/rbt-Attachment cc: Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector Arkansas Nuclear One - ANO-1 Number 1, Nuclear Plant Road Russellville, AR 72801 Ms. Greta Dicus Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72201 I

\ .

A I

, STATE OF ARKANSAS )

) SS l COUNTY OF PULASKI )~ -

I, T. G. Campbell, being duly sworn, subscribe to and sey that I am l

+

Vice President, Nuclear for Arkansas Power & Light Company; that I have full ;

authority to execute this oath; that I have read the document numbered SCAN 188981 and know the contents thereof; and that to the best of my knowledge, information and belief, the statements in it are true, WW '

T. G. CampB 1 SUBSCRIBE 0 AND SWORN TO before me, a Notary Public in and for the County and State above neaned, this May of 8M'6 L/ ,

1989.

1

(.- -

ON Notary Public My Commission Expires:

A/90/%

y l

l

7_

t

)

, 1 l

1 l

L  !

)

1  ;

ATTACHMENT  !

1 PROPOSED TECHNICAL SPECIFICATION CHANGES {

m l LICENSE AMENDMENT REQUEST I t

IN THE MATTER OF AMENDING .!

LICENSE NO. DPR-51  !

I LICENSE NO NPF-6 ARKANSAS POWER & LIGHT COMPANY

{

ARKANSAS NUCLEAR ONE, UNIT 1 h ARKANSAS NUCLEAR ONE, UNIT 2 .!

~!

DOCKET NO. 50-313

{

DOCKET NO. 50-368 7

f OCTOBER 12, 1989 I

l

. t t-

~!

I k

l l

l k

l, l

t

DESCRIP110N OF PROPOSED CHANGE i

AP&L proposes to change ANO-1 Technical Specification (TS) 4. " Surveillance i Requirements", and ANO-2 TS 4.0.2 and the related Bases, in accordance with '

NRC guidance transmitted by Generic Letter 89-14. The proposed changes will -l remove the 3.25 cumulative limit on extending surveillance intervals. The i existing "minus 25 percent" limit for reducing surveillance intervals on i ANO-1 is also proposed to be removed.

BACKGROUND )

Specification 4.0.2 of the Standard Technical Specifications permits  !

surveillance intervals to be extended up to 25 percent of the specified I interval. This extension facilitates the scheduling of surveillance i activities and allows surveillances to be postponed when plant conditions are not suitable for conducting a surveillance, for example, under transient  ;

conditions or other ongoing surveillance or maintenance activities.

Specification 4.0.2 also limits extending surveillances so that the combined time interval for any three consecutive surveillance intervals shall not r exceed 3.25 times the specified surveillance interval. The intent of the 3.25 limit is to preclude routine use of the provision fcr extending a i surveillance interval by 25 percent.

Commmonwealth Edison Company (CECO) submitted a lead plant proposal for the LaSalle Technical Specifications (TS) to remove the 3.25 limit for surveil-lances that are performed during a refueling outage and are specified with an 18-month surveillance interval. After discussions with the NRC staff, CECO amended the pt oposal to remove the 3.25 limitation for all  ;

surveillances. The amended proposal was approved by the NRC staff on a lead plant basis. Consistent with NRC policy, Generic Letter 89-14 provided guidance for license amendment requests to implement this line-item improvement in TS.

The basis for the 25 percent reduction limitation, which was part of the ,

original ANO-1 Technical Specification, is not clear. We are unaware of any benefit this limitation provides. A literal interpretation of this ,

specification precludes AP&L from taking credit for a surveillance test if performed prior to the specified interval minus 25 percent.

DISCUSSION l Experience has shown that the 18-month surveillance interval, with the j provision to extend it by 25 percent, is usually sufficient to accommodate  ;

However, the NRC staff has normal variations in the length of a fuel cycle.

l routinely granted requests for one-time exceptions to the 3.25 limit on extending refueling surveillances because the risk to safety is low in l contrast to the alternative of a forced shutdown to perform these l surveillances. Therefore, the 3.25 limitation on extending surveillances l

has not been a practical limit on the use of the 25 percent allowance for l extending surveillances that are performed on a refueling outage basis.

l The use of the allowance to extend surveillance intervals by 25 percent can also result in a significant safety benefit for surveillances that are performed on a routine basis during plant operation. This safety benefit is

'e incurred when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillance. Examples of this include transient plant operating conditions or conditions in which safety systems  !

are out of service because of ongoing surveillance or maintenance activities.

In such cases, the safety benefit of allowing the use of the 25 percent [

allowance to extend a surveillance interval would outweigh any benefit derived by limiting three consecutive surveillance intervals to the 3,25 limit.  !

Also, there is the administrative burden associated with tracking the use of i the 25 percent allowance to ensure compliance with the 3.25 limit. On the basis of these considerations, the NRC staff concluded that removal of the '

3.25 limit will have an overall positive impact on safety.

Removal of the 25 percent reduction limitation for surveillance intervals on ANO-1 will make the general surveillance performance requirements more '

similar to those in the STS. This limitation provides no safety benefit and is not included in the STS. Performance of surveillance activities more  :

frequently than the specified intervals does not alter the assurance of i reliability that surveillance activities provide.

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION AP&L has performed an analysis of the proposed changes in accordance with ,

10CFR50.91(a)(1) regarding no significant hazards consideration, using the criteria in 10CFR50.92(c), as follows: ,

(1) The proposed changes do not increase the probability or consequences of any accident previously evaluated, because the surveillance interval limitations which would exist under the proposed change have been evaluated by the NRC and determined to remain adequate. The specific  :

interval reduction limit for AND-1 unnecessarily prevents surveillances from being performed more of ten than required; its removal will not increase the probability or consequences of previously evaluated accidents.

(2) The proposed changes do not create the possibility of a new or l different kind of accident from any previously evaluated, because the limits on surveillance interval extensions and reductions do not create any new accident precursors or scenarios.  ;

(3) The proposed changes do not involve a significant reduction in a margin  ;

of safety. As discussed in GL 89-14 and above, use of the allowance to extend surveillance intervals by 25 percent can, in fact, result in a significant safety benefit for surveillances that are performea on a routine basis during plant operation. The specific interval reduction limit for ANO-1 has no significant safety benefit. Performance of more frequent surveillance activities is allowed under the Standard Technical Specifications. Removal of this limit for ANO-1 will therefore not involve a significant reduction in a margin of safety. The proposed surveillance interval tolerance values continue to assure that the reliability associated with surveillance activities is not significantly degraded beyvnd that obtained from the nominal specified intervals.

. g., _ - .- - . - -_- _ - - _ _

V m; .

e  :  !

' l' L,- i The Commission has provided guidance for amendments that are considered not likely to involve a significant hazards consideration (51FR7750). The proposed amendment does not closely match any of the examples. The proposed  !

amendment is submitted in response to NRC recommendations for proposed changes j as transmitted to AP&L as GL 89-14. ,

t

. , Therefore, based on the above and the previous discussion of.the amendment

.q request, AP&L has determined that the requested change does.not involve a j

-significant hazards consideration.  ;

i I

~ t f

I i

l

'~ '

I

'f r  !

[ -f s

e  !

b  ;

L l

L  :

l  !

I l

I [

i I

i

- -n-w - , m n ----., - e,, e w- .w-7, ,-r-~,,e, - e