ML19327C209
| ML19327C209 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/14/1989 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19327C210 | List: |
| References | |
| GL-89-14, ULNRC-2107, NUDOCS 8911210167 | |
| Download: ML19327C209 (7) | |
Text
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Mail Station F1-137 Washington, D.C.
20555 Gentlement ULNRC -2107 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SFECIFICATION 4.0.2 SURVEILLANCE INTERVALS Union Electric Company herewith transmits an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This amendment application revises Technical Specification 4.0.2 and its associated' bases to remove the 3.25 limit for surveillances as provided in Generic Letter 89-14 dated August 21, 1989.
Attachments 1, 2, and 3 contain the Safety Evaluation, the.Signifi-l cant Hazards Evaluation, and the Proposed Technical Specification Changes in support of this amendment request. The proposed change l
will become effective for Union Electric implementation upon NRC approval.-
Very truly yours, l
Donald F. Schnell JMC/rbs Attachments s
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' Alan C. Passwater, of lawful age, being first duly: sworn upon oath says that he is Manager, Licensing and Fuels (Nuclear) for.
Union-Electric Company; that he has read the foregoing document and
.knows the content thereof;-that'he has executed the same for and on-behalf of said company with full power and authority to do.so; and that the-facts therein stated are true and correct to'the best of'his.
.-knowledge, information and belief.
By Alan C.
Passwater Manager, Licens$ng and Fuels Nuclear I
SUBSCRIBED and sworn to before me this M
day of ViA*4zd 1989 l
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f Attcchmtnt 1, Pcg3 1 of 2 ULNRC - 2107 Safety Evaluation This amendment request revices Technical Specification 4.0.2 and its associated Bases to remove the 3.25 limit for surveillances as provided in Generic Letter 89-14 dated August 21, 1989.
This change and its respective safety evaluation is discussed hereinafter.
g Technical Specification 4.0.2 permits surveillance intervals to be extended up to 25% of the specified surveillance interval.
This extension facilitates the scheduling of surveillance activities and allows surveillances to be postponed when plant L
conditions are not suitable for conducting a surveillance.
Specification 4.0.2 also limits extending surveillances so that the combined time interval for any three consecutive surveillance intervals shall'not exceed 3.25 times the specified surveillance interval.
The intent of the 3.25 limit is to preclude routine use of the provision for extending a surveillance interval by 25%.
The use of the allowance to extend surveillance intervals by 25% can also result in a significant safety benefit for surveillances that are performed on a routine basis during plant operation.
This safety benefit is 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 cafety systems are out of service because of ongoing j
surveillances or maintenance activities.
.In such cases, the safety benefit of allowing the use of the 25% 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 the 25% allowance to ensure compliance with the 3.25 limit.
On the basis of these considerations, it can be concluded that removal of the 3.25 limit will have an overall positive impact on safety.
The proposed change to the surveillance requirement will not I
increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
The change merely removes an unnecessary restriction on extending surveillance requirements and will result in a benefit to plant safety when conditions are not conducive to the safe conduct of surveillance requirements.
The proposed change to the surveillance requirement will not create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report.
The proposed change does not involve changing L
any setpoints or involve changing how existing equipment is operated.
The change clarifies the surveillance by removal of i
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- ULNRC - 2107 the 3.25 limit, thus'providing greater flexibility in the use of the. provision for extending surveillance intervals.
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The proposed; change to the surveillance requirement will not affect the margin ~of safety as defined in the basis for any technical specification.
The removal of the 3.25 limit reduces the. administrative burden associated with its use, and will have i'
a positive effect on safety.
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Pursuant to the above information, as provided per Generic i
Letter 89-14, this amendment request does not adversely affect or L
endanger the health or safety of the general public and does not
. involve an unreviewed' safety question, i
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E Attachmtnt 2, Pcga 1 of 1 ULNRC-2107
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Significant Hazards Consideration This. amendment request revises Technical Specification 4.0.2 and its associated Bases to-remove the 3.25 limit for surveillances as provided in Generic Letter 89-14,. dated August.21, 1989.
This change and its respective significant hazards evaluation is discussed hereinafter.
The proposed change to the surveillance requirement does not' involve a significant increase in the probability or consequences of an accident previously evaluated.
The change merely is an effort to clarify, simply,and streamline the specifications in accordance with the guidance provided in Generic Letter 89-14.
The proposed change to the surveillance requirement does not create the possibility of a new or different kind of accident from any previously evaluated.
The change does not alter the' requirements and the method and manner of plant operation are unchanged.
It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for. conducting the surveillance.
The proposed change to the surveillance requirement does not involve a significant reduction in a margin of safety.
The change does not effect any technical specification margin of safety, and it provides clarification for performance of surveillance requirements and will have an overall positive impact on safety.
Based on the above discussions it has been determined that the requested Technical Specification revision does not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety.
Therefore, the requested license amendment does not involve a significant hazards consideration.
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