ML19332C410

Application for Amend to License NPF-47,revising Tech Specs to Allow Removal Tolerance Limit 3.25 on Three Consecutive Surveillance Intervals,Per Generic Ltr 89-14

ML19332C410
Person / Time
Site:	River Bend
Issue date:	11/17/1989
From:	Deddens J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19332C411	List: ML19332C410 ML19332C412
References
GL-89-14, RBG-31780, NUDOCS 8911280090
Download: ML19332C410 (7)

Text

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GULF STATES UTILITIES COMPANY

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A8418 0091f,A L ?! 6'*ka 34E M M ll November 17, 1989 i'

RBG- 31780

" File Nos G9.5, G9.42 U.S. Nuclear Regulatory Commission Document Control Desk s Washington, D.C. 20555 Gentlemen: .

' River Bend: Station - Unit 1 Docket No. 50-458 Gulf States Utilities (GSU) Company hereby files an application to amend the River Bend Station -: Unit 1 Technical Specifications. Appendix A to Facility Operating License NPF-47, pursuant to 10CFR50.90.- This application is filed to 85'-14.

request changes

.These changesin accordance will allow the withremoval guidance provided of the in Genericlimit 3.25 tolerance Letter on three consecutive surveillance intervals. The attachment to this letter and its enclosures provide the justifications and proposed revisions to the Technical Specifications and Bases, h

n Your prompt attention to this applicotion.is appreciated.

.. Sincerely 6 ,thn J. C. Deddens Senior Vice President River Bend Nuclear Group Attachments p- .

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8911280090 801117 PDR P

ADOCK 05000458 kk '

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m cc: U. S. Nuclear Regulatory Comission

, 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Mr. Walt Paulson, Project Manager U.S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC Resident inspector P. O. Box 1051 St. Francisville LA 70775 Mr. William H. Spell, Administrator Nuclear Energy Division Louisiana Dept. of Environmental Quality

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P. O. Box 14690 Baton Rouge,i.A 70898 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

t STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )  !

Docket No. 50-458 In the Matter of )  !

GULF STATES UTILITIES COMPANY )

(River Bend Station - Unit 1) h AFFIDAVIT l J. C. Doddens, being duly sworn, states that he is a ,

Senior Vice President of Gulf States Utilities Company; that ;

he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached  :

hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

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J. Cg/Deddens' Subscribed and sworn.to before me, a Notary Public in and j Parish above named, this / 1 1"-

for the State and day of 71&Lt.nt/uA , 19 9 . My Commission expires with Life.

OLA C C ,

Claudia F. Hurst Notary Public in and for West Feliciana Parish, Louisiana l

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. D ATTACHMENT PROPOSED i GULF STATES UTILITIES COMPANY L RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47 i

REMOVAL' OF 3.25 SURVEILLANCE INTERVAL LIMIT L

(89-04)

LICENSING DOCUMENT INVOLVED: TECHNICAL SPECIFICATION 4.0.2

> REASON FOR REQUEST:

A proposed change is being requested in occordance with 10CFR50.90 to '

s provide the necessary Technical Specification changes to allow the removal of the 3.25 limit on three consecutive ~ surveillance intervals from the Technical Specifications in accordance with guidance provided in Generic Letter 89-14 dated August 1989. The proposed change would

. maintain the present maximum allowance of 25 percent for those surveillances which can apply the tolerance of 4.0.2.

The proposed change will provide a reduction of the administrative burden on GSU while still niaintaining the maximum extension on individual surveillance intervals contained in the present specification.

DISCUSSION Specification 4.0.2 of the Standard Technical Specifications permits surveillance intervals to be extended up to 25 percent of the specified interval. This extension facilitates the scheduling of surveillance 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 exceed 3.25 times the specified surveillance i nter'- :1. The intent of the 3,25 limit is to preclude routine use of i the provision for extending a surveillance interval by 25 percent.

Generic Letter 89-14, August 21. 1989, entitled " Removal of the 3.25 Limit on Extending Surveillance Intervals" contains guidance for an option to remove.the 3.25 limit from Specification 4.0.2 while retaining  ;

the 25 percent maximum allowance to extend surveillance intervals. The j use of the allowance to extend surveillance intervals by 25 percent can 1 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.

7 Also, there is the administrative burden associated with tracking the Page 1 of 4 r

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use of the 25 percent allowance to ensure compliance with the 3.25 limit. On the basis of these considerations, removal of the 3.25 limit is expected to have an overall positive impact on safety.

The Generic Letter identifies the repeated use of the 25 percent i

extension as a convenience is not the intent of the guidance. To address this concern GSV will remove the 3.25 limit from the License but maintain the criteria as an administrative limit in the plant procedures and require management review prior to exceeding to 3.25 criteria;

! therefore limiting the repeated use. A review of past surveillances performed at RBS for the period from 1986 through September 1989 provides further proof the 3.25 criteria will usually be observed. In this period approximately 20,219 surveillances, with intervals greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, were performed with about less than five percent  ;

perfomed greater than the nominal (1.0) time limit.

As a result of the extended first cycle operation River Bend Station (RBS) requested numerous extensions to the 1.25 limit of 4.0.2.a to reach the first refueling outage. The extensions received at that time will result in a number of surveillances reaching the 3.25 limit between the scheduled mid-cycle outage and the third refueling outage. These surveillances cannot be conducted during normal operations and therefore would require extending the mid-cycle outage. These tests include the Division III diesel generator inspections Division I, II ECCS tests and the Drywell bypass leakage test and could extend tha outage from a planned 14 day outage to a 24 day outage. None of these items will exceed the 1.25 limit prior to the third refueling outage. Approval of  ;

this- request will allow this testing to be conducted-during the third refueling outage.

As a result of the proposed change to the Technical Specifications a revision to the BASES has been identified which are necessary. The proposed revisions are contained in Enclosure II. The change to the basis for Specification 4.0.2 follows the guidance provided in the Generic Letter. Because these changes involve only the Bases, there are no changes or modifications made to the River Bend facility or Technical Specifications per 10CFR50.56 and no changes to any existing Limiting Condition for Operation, Surveillance Requirement, or margin of safety.

Therefore, this change does not 1) increase the probability or consequences of an accident previously evaluated, 2) create the possibility of a new or different kind of accident from any previously evaluated, or 3) reduce the margin of safety.

NO SIGNIFICANT HAZARDS CONSIDERATIONS In accordance with the requirements of 10CFR50.92, a no Significant Hazards Considerations evaluation is performed for the technical specification changes described in the preceding paragraphs. Based on the guidance provided in NRC Generic Letter 89-14, the proposed change removes the 3.25 surveillance interval from the RBS Technical Specifications. The change does not involve a significant hazards  ;

consideration for the following reasons: .

The propesed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated Page 2 of 4

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because the 3.25 surveillance interval extension criteria of (

Technical Specification 4.0.2 was not considered in the plant accident analysis (SAR Chapter 15).

The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated s because the surveillance interval will still be constrained by the

! 25 percent interval extension criteria of Technical Specification 4.0.2.

The proposed amendment does not involve a significant reduction in i the margin of safety because deletion of the requirement "any three consecutive intervals must not exceed 3.25 times the interval" will o not significantly effect equipment reliability. This exemption will -

allow all surveillance intervals to be constrained by the maximum allowable extension of 25 percent of the specified surveillance

interval which will maintain safe operation when used during plant operation. Normal scheduling would still be at the specified

surveillance interval. <

Based upon the above considerations, the proposed change does not result in a significant increase in the probability or the consequences of any accident previously evaluated, does not create the possibility of a new or different kind of accident than previously evaluated and does not

~sult in a reduction in the margin of safety. Therefore, GSV proposes that no significant hazards considerations are involved with approval of the proposed change.

REVISED TECHNICAL SPECIFICATIONS The requested revisions are provided in Enclosure I. The revised Bases are included as Enclosure II. '

SCHEDULE FOR ATTAINING COMPLIANCE River Bend Station is currently in compliance with the applicable Technical Specifications. GSU requests this proposed change be approved prior to the mid-cycle outage to allow those 18 month surveillances which require an extension of the mid-cycle outage to be delayed until the third refueling outage.

NOTIFICATION OF SYATE PERSONNEL A copy of the amendment application and this submittal is being provided to the State of Louisiana, Department of Environmental Quality-Nuclear i Energy Division.

ENVIRONMENTAL IMPACT APPRAISAL, Gulf States Utilities Company (GSU) has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations. As shown above, the proposed changes do not involve a significant Fazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the Page 3 of 4

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foregoing, GSU concludes'that the' proposed changes meet the . criteria given in 10CFR51.22(c)(9) for a- categorical exclusion from the requirement for an Environmental Impact Statement.

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