ML20005G849

Application for Amend to License DPR-50,consisting of Tech Spec Change Request 197,removing 3.25 Limit on Extending Surveillance Intervals,Per 890821 Generic Ltr 89-14

ML20005G849
Person / Time
Site:	Three Mile Island
Issue date:	01/08/1990
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20005F794	List: ML20005F793 ML20005F797 ML20005G849
References
GL-89-14, NUDOCS 9001230191
Download: ML20005G849 (5)

Text

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METROPOLITAN EDISDN COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY i

AND i PENNSYLVANIA ELECTRIC COMPANY l

THREE MILE ISLAND NUCLEAR STATION; UNIT 1 i

l Operating License No. DPR-50 Docket No. 50-289 .j Technical Specification Change Request No. 197 l l

l This Technical Specification Change Request is submitted in support of Licensee's i request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. As a part of this request, proposed replacement pages for Appendix A are also included, i GPU NUCLEAR CORPORATION  !

. BY: \ -

Vice Presi' dent & Director, TMI-1 Sworn and subscribed

, to before me this 80 {

8 day of ham I, ,1990.

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/~ Notary Public ShamnP Drown, atryPsic M JW1 i

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. UNITED STATES OF AMERICA I l

NUCLEAR REGULATORY C0!HISSION l

IN THE MATTER OF DOCKET NO 50-2B9  !

GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 l

I CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 197  ;

to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has,.on the date given below, been filed with executives of Londonderry Township, Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; and the i Pennsylvania Department of Environmental Resources, Bureau of Radiation  ?

Protection, by deposit in the United States mail, addressed as follows:

i Mr. Kenneth E. Witmer, Chairman Ms. Sally S. Klein, Chairman Board of Supervisors of Board of County Commissioners  :

Londonderry Township of Dauphin County  :

25 Roslyn Road Dauphin County Courthouse Elizabethtown, PA 17022 Harrisburg, PA 17120 ,

i Mr. Thomas Gerusky, Director ,

PA. Dept. of Environmental Resources -

Bureau of Radiation Protection >

P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR CORPORAT.10

, BY:  !

Vice President & Director, TMI-1 DATE: January 8, 1990 l

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I. TECHNICAL SPECIFICATVON CHANGE REOUEST (TSCR) NO. 197 GPUN requests that the foll> wing changed replacement pages be inserted into the existing Technical Specifications:

Revised pages: 1, 1-7, and 1-8 These pages are attached to this change request.

II. REASON FOR CHANGE This change is requested to modify the THI-1 Technical Specifications to remove the 3.25 limit on extending surveillance intervals and to add the Bases for the existing 25% allowance, in accordance with the guidance contained in NRC Generic Letter 89-14, dated August 21, 1989. This change incorporates a line-item improvement in Technical Specifications by removing an unnecessary restriction on extending surveillance requirements and provides a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements.

This change also modifies the THI-1 Technical Specification to be consistent with Standard Technical Specifications by including FREQUENCY NOTATION as a Technical Specification definition. Associated with this modification, the existing Technical Specification provision allowing survalliance interval extensions of a maximum of 25% is relocated from the existing Technical Specification Table 1.2 to the new FREQUENCY NOTATION definition, since this extension is currently applicable to all surveillance intervals specified within the Technical Specification.

III. SAFETY EVALUATION JUSTIFYING CHANGE THI-1 Technical Specification Table 1.2, Footnote "B", which currently specifies that a total maximum combined interval time for any three consecutive tests is not to exceed 3.25 times the specified surveillance interval, is removed, and the Bases for the existing 25% allowance is added in accordance with guidance contained in NRC Generic Letter 89-14.

The existing Table 1.2 Footnote "A",-which is being relocated to the new FREQUENCY NOTATION definition, permits a maximum allowable extension of 25% of all normal surveillance intervals to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance (e.g. transient conditions, or other ongoing surveillance or maintenance activities).- It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with a fuel cycle length surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.

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• The ute of the allowance to extend surveillance intervals by 25% provides a safety benefit when a surveillance interval is extended at a time that conditions are not suitable for performing the surveillance. Examples include transient plant operating conditions or conditions in which safety systems are out of service because of ongoing surveillance or maintenance activities. The safety benefit of allowing the use of the 25% allowance to extend a surveillance interval in such cassa outweighs any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. Therefore, there is an overall positive effect on safety.

The administrative burden of tracking the use of the 25% allowance to ensure compliance with the 3.25 limit is also eliminated. ,

Addition of Technical Specification 1.25 FREQUENCY NOTATION is an f administrative change to be consistent with the Standard Technical Specification in this area. Relocation of the existing Footnote "A" on Table 1.2 is also an administrative change to clarify that the maximum surveillance interval extension of 25% is applicable to all surveillance  ;

intervals specified within Technical Specifications and is not limited to surveillance intervals designated by the FREQUENCY NOTATION of Table 1.2.

IV. HO SIGNIFICANT HAEARDS CONSIDERATIONS ,

CPUN has determined that this Technical Specification Change Request involves no significant hazards consideration as defined by NRC in  :

10 CFR 50.92,

1. Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of '

occurrence or the consequences of an accident previously evaluated.

The proposed amendment removes the 3.25 limit on extending surveillance intervals and adds the Bases statements for the existing 25% allowance, in accordance with the guidance contained in NRC Generic Letter 89-14. . Removal of the 3.25 limit on extending surveillance intervals provides a safety benefit by allowing a surveillance interval to be extended at a time that conditions are I not suitable for performing the surveillance (e.g.. transient plant operating conditions or other ongoing surveillance or maintenance i activities). The safety bencfit of allowing the use of the 25%

allowance to' extend a surveillance interval in such cases outweighs ,

any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. This change does not involve any change i to the actual surveillance requiren.ents. The reliability ensured  ;

through surveillance activities is not significantly degraded beyond

• that obtained from the speelfied surveillance interval.- The addition of Technical Specification 1.25 FREQUENCY NOTATION is an ,

administrative change to achieve consistency with Standard Technical i specifications, and relocation of the existing provision to allow a  ;

maximum surveillance interval extension of 25%, from Table 1.2 to the new definition only provides clarification that this extension is- '

applicable to all Technical Specifications surveillance requirements.

Therefore, this change does not increase this probability of l

occurrence or the consequences of an accident previously evaluated.

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• 2. Operation of the f acility in accordance with the proposed amendnent  !

would not create the possibility of a new or different kind of  !

accident from any accident previously evaluated. This change does not involve any change to the actual surveillance requirements and i allows a surveillance interval to be extended at a time that ,

conditions are not suitable for performing the surveillance. ,

Therefore, this change has no effect on the possibility of creating a new or different kind of accident from any accident previously evaluated.

3. operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Removal of the 3.25 limit on extending surveillance intervals provides a positive effect on safety by allowing a surveillance interval to be extended at a time that conditions are not suitable for performing the surveillance. The safety benefit of allowing the use of the 25% allowance to extend a surveillance interval in such cases outweighs any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. This change does not involve any change to the actual surveillance requirements. The reliability ensured through surveillance activities is not significantly degraded beyond that obtained from'the specified surveillance interval. The addition of Technical Specification 1.25 FREQUENCY NOTATION is an administrative change to achieve consistency with Standard Technical Specifications, and relocation of the existing provision to allow a maximum surveillance interval. extension of 25%, from Table 1.2 to the new definition only provides.

clarification that this extension is applicable to all Technical Specifications surveillance requirements. Therefore, it is concluded that operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin of safety.

The commission has provided guidelines pertaining to the application of the three standards by listing specific examples in 45 FR 14870. The proposed amendment is considered to be in the same category as example (1) of amendments that are considered not likely to involve significant hazards consideration in that the proposed change constitutes a purely administrative change to Technical Specifications. This change is similar in that~it '

implements the guidance contained in NRC Ceneric Letter 89-14 for removal of the 3.25 limit on extending surveillance intervals, provides additional consistency with Standard Technical Specifications and clarification of the applicability of the existing 25% allowance. Implementation of the proposed amendment in accordance with the generic letter guidance provides an overall positive effect on safety, eliminates the administrative burden of tracking the use of the 25% allowance to ensure compliance with 3.25 limit, and implements a line-item improvement in Technical Specifications. Thus, operation of the facility in accordance with the proposed amendment involves no significant hazards considerations.

V. IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance.

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